Conflict of Interest Disclosure: Maintaining Institutional Integrity
The University is committed to the highest standards of transparency and ethical conduct. To ensure we remain compliant with tax and regulatory requirements, all employees are required to participate in our dual-disclosure process.
We want to thank you for taking your reporting obligations seriously. Whether you are providing a yearly certification or disclosing a new opportunity, your transparency protects both you and the University from perceived or actual bias. Most disclosures are simply managed with a straightforward plan, allowing our community to pursue outside professional opportunities with confidence.
Which Form Should You Complete?
This is the mandatory yearly filing for the Current Period (May 1 – April 30). It is a look-back at your activities over the past fiscal year to certify your Independent status and confirm all Business Transactions or Material Interests have been recorded.
*This form will be distributed on an annual basis via Qualtrics.
This form must be submitted prior to a known conflict arising. If you are planning to accept a new board seat, start a Related Entity, or enter into a Business Relationship with an Interested Person, you must disclose it here before the activity begins.
†This form is in development and will be posted when available.
Filing Resources
The full governing document detailing University expectations and legal requirements for all employees and Interested Persons.
Conflict of Interest Definitions and FAQ
A guide breaking down key terms – such as Family Member, Compensation and Related Entity – with answers to common filing questions.
Privileged Relationship Exception Guide
Instructions for attorneys, medical professionals, and clergy on how to disclose business roles while maintaining professional confidentiality.
A tool to help you determine if your research responsibilities categorize you as a Principal Investigator or Project Director.
Summary of Reporting Thresholds
A quick-reference table outlining the specific dollar amounts (e.g., $5,000 and $10,000) that trigger a mandatory disclosure.
Guide to Independent Status
A resource for Trustees and Board members to navigate the four-part test required to certify as Independent for the fiscal year.
How Your Disclosure is Reviewed
Once a disclosure is submitted, it is routed to a designated Reviewer for evaluation. The review process determines if a disclosed interest constitutes a conflict that requires a formal Management Plan.
If you are a Reviewer, or if you have been asked to participate in the evaluation of a potential conflict involving a Principal Investigator or Project Director, please use the official review tool to document the determination and any necessary mitigation steps.