Conflicts of Interest and Commitment
Annual Disclosure Information for all EHRA Employees
The University recognizes that conflicts of interest are inherent in the work that we do. With this recognition comes a responsibility to disclose and manage those conflicts that allow us to pursue our work ethically and responsibly, preserving both academic freedom and public trust. Conflicts of interest predominantly arise from an individual’s financial interest in an external entity, but they may also arise from other activities or relationships that can result in bias or the appearance of bias in carrying out our institutional responsibilities.
A financial interest is anything of economic value, including a fiduciary duty with an entity external to the University. Examples include, but are not limited to, positions such as director, officer, partner, consultant or manager of an entity (paid or unpaid); salaries; consulting income; equity interests; honoraria; gifts; loans; and travel payments. Any financial interest related to professional employment must be reported.
All EHRA employees, regardless of employment status, must complete a Conflict of Interest disclosure at least annually as a condition of employment. The annual disclosure period begins on July 1 and ends on April 30. Annual disclosures must be submitted through the Conflicts of Interest Risk Manager system no later than April 30.
Project Specific Disclosure Information for ECU Personnel
In addition to annual disclosures, externally sponsored research projects require that ECU personnel paid from project funds submit a project specific disclosure, and when applicable, that certain subrecipients and contractors submit disclosures. See ECU’s Disclosures for Sponsored Projects to learn more.
Conflict of Interest Defined
A conflict of interest relates to situations in which financial or other personal considerations, circumstances, or relationships may compromise, involve the potential for compromising, or have the appearance of compromising an employee’s objectivity in fulfilling their University duties or responsibilities, including research, service, teaching activities, and administrative duties.
Conflicts of Interest may fall within one of four different categories that guide ORIC’s review and disposition of identified conflicts or potential conflicts. To learn more about how these are categorized, refer to the COI Categories page.
Interactions with industry and other outside entities also have the potential to create conflicts of commitment insofar as such activities may interfere with an individual’s ability to carry out his or her primary responsibilities to ECU.
Conflict of Commitment Defined
Conflict of Commitment (COC) relates to an individual’s distribution of time and effort between obligations to University employment and participation in other activities outside of University employment. The latter may include such generally encouraged extensions of professional expertise as professional consulting (i.e. External Professional Activities for Pay). Such activities promote professional development and enrich the individual’s contributions to the institution, to the profession, and to society. However, a conflict of commitment occurs when the pursuit of such outside activities involves an inordinate investment of time or is conducted at a time that interferes with the employee’s fulfillment of University Employment Responsibilities.
External Professional Activities for Pay (EPAP)
EHRA employees may sometimes engage in an External Professional Activity for Pay. When doing so, the employee must provide satisfactory assurances that such activity will not interfere with University employment obligations. External Professional Activities for Pay should generally be limited to no more than the equivalent of 20 percent (20%) of an employee’s full-time status equivalent.
Notice of Intent to Engage in External Professional Activity for Pay
A Notice of Intent to Engage in an External Professional Activity for Pay must be submitted and approved by an immediate supervisor for each separate activity in which the employee wishes to engage. The Notice of Intent is to be completed in the COI Risk Manager system at least ten calendar days in advance of the planned engagement in a professional activity for pay.
In addition, employees must disclose any financial interest related to an external professional activity for pay in his or her annual COI disclosure for activities in which financial compensation was received during the previous 12 months.
More information about External Professional Activities for Pay may be found in the EPAP Quick Reference.