East Carolina University Faculty Manual

APPENDIX I.

ECU POLICY ON CONFLICTS OF INTEREST AND COMMITMENT

V. Submission of Conflict Evaluation Forms (Disclosures).

Policy: Effective July 1, 1995, each faculty member and all other EPA employees will be required to disclose annually for both him/her selves and their immediate families (see definition in Section IX) the extent of their relevant external activities and relationships and their financial holdings that are related to the employee’s university activities. These university activities include but are not limited to sponsored research activities. These external activities, relationships and financial holdings are described above in Section IV under Categories II & III. All potential Category II and III relationships or financial holdings must be reported regardless of the dollar amounts involved. Category I activities and relationships are not required to be disclosed under this policy; however, other university reporting requirements may apply to these activities (see Section IV). Where there is some question whether an activity should be considered a Category I or II activity as described above, the faculty/EPA non-faculty employee should include the activity in the disclosure for consideration by his/her supervisor.

All faculty and other EPA personnel are charged by the University to provide a full good faith disclosure. Failure to provide such a full disclosure may be considered a serious breach of this policy and may be cause for disciplinary action (see Section VIII).

Revisions or updates of the yearly disclosures are required between yearly disclosures whenever there is a significant change in the faculty member’s or his immediate family’s affairs that may lead to or may be perceived to lead to a conflict with the faculty member’s university activities, e.g., the faculty member’s spouse begins to receive consultant fees from a company that currently contracts with university for research services from the faculty member’s laboratory.

Procedures: To facilitate disclosure and to ensure appropriate uniformity across the University, each individual will complete the "Annual Faculty/Professional Staff Disclosure Form." Each unit administrator will distribute this form annually to all faculty and professional staff (EPA non faculty) under his or her supervision and assure that completed forms are returned.

The purpose of this form is to identify employees' activities that may lead to actual or potential conflicts of commitment or interest so that appropriate administrative intervention may address the problems. The employee and the administrative superior are to complete and sign the annual disclosure form, which implies that the administrative superior has reviewed the form. No further action will be required if all questions are answered "no".

Further disclosure and review are required if questions elicit any "yes" responses on the Annual Faculty/Professional Staff Disclosure Form or on any mid year revisions or updates of the annual form. The employee must then complete and sign the appropriate additional forms. Suggested provisions or plans for eliminating or managing conflicts should be included in these additional forms where indicated. Examples of some (but not all) possible provisions for conflict management plans are:

1. Public disclosure of the significant financial interests or external activities

2. Monitoring of activities by disinterested university officials to assure that conflicts do not arise.

3. Cessation of the pertinent outside activities

4. Divestiture of the pertinent financial interests

5. Severance of the relationships that create actual or potential conflicts

Since these forms have direct bearing on the employment of individuals with the University, all disclosure forms (the annual form and accompanying forms) and associated documents will be maintained in the administrative office of the employee's unit in his/her personnel folder for a period of at least three years following termination of the pertinent activities.