Staff Conflict of Interest and Commitment Process

All members of the Brown Community are responsible for complying with the University's Conflict of Interest and Commitment Policy and its related guidelines. The Policy requires annual disclosure, in addition to disclosing potential, actual, or perceived conflicts as they arise to their supervisor or assigned senior administrator.

Click here for instructions on how to launch the Conflict of Interest and Commitment Process in Workday and complete the annual disclosure form or disclosure update.

I. Annual Conflict of Interest and Commitment Disclosure Process

The Conflict of Interest and Commitment Disclosure process is launched annually via Workday. All staff members except seasonal and intermittent staff are required to complete a Conflict of Interest and Commitment Disclosure form annually as a condition of employment. Please note that while seasonal and intermittent staff are excluded from the annual disclosure process, they are still subject to the Conflict of Interest and Commitment Policy. The full disclosure of potential, actual, or perceived conflicts of interest or commitment is necessary to determine whether the activity is permitted.

Disclosure Period

The annual disclosure period is January to December of the prior year.  Financial information (e.g. additional compensation, ownership interest, gifts) should be provided for the previous calendar year (January to December) to align with income forms/statements and preparation of annual tax filing. Business and professional commitments and relationships with family members who are also Brown staff members should be disclosed at the time when they come into effect.

Annual Reporting Process

Refer to the Conflict of Interest and Commitment Guidelines in the Resources section below when completing the following steps in the process:

  1. In February, all staff members except seasonal and intermittent staff receive an email with a link to instructions on how to launch and complete the Conflict of Interest and Commitment Disclosure process in Workday.
     
  2. Staff answer ten Yes/No questions on the Conflict of Interest and Commitment Disclosure form ("yes" answers require additional information). Managers are responsible for reviewing all disclosure forms and determining whether the conflict requires a management plan. Managers work with their staff member and senior administrator to develop a management plan using information from the Conflict of Interest and Commitment Management Plan as a guide.
  3. In cases where a disclosure is made that identifies a potential, actual, or perceived conflict, the disclosure form and management plan, if needed, are reviewed by designated Conflict of Interest and Commitment reviewers; some reported disclosures may require further review by a Conflict of Interest and Commitment Review Committee that may consist of staff representation from the Finance Division; University Risk Management, Audit & Compliance; University Human Resources, and others as deemed appropriate; if necessary, the Office of General Counsel may also review and advise. 

Forms are required to be completed by the end of March.

II. Disclosure Updates

Staff members are required to complete a new disclosure form at the time that a new potential, actual, or perceived conflict arises; for example, election to a public office or the hiring of a family member where the staff member is in a role which could influence decisions.  A new disclosure form can be requested in Workday using the Create Request task. See below for policy links and other resources.

III. Roles & Responsibilities

Manager
● Managers must ensure all staff members complete the Conflict of Interest and Commitment Disclosure form in Workday.
● Once submitted, managers must review the forms to ensure the conflict situation is accurately reflected.
● Managers are responsible for working with staff members to assess whether a management plan is required to address a potential, actual, or perceived conflict of interest or commitment.
● If a management plan is required, managers must work with staff members to develop a plan that appropriately addresses the situation.
● If a new conflict arises during the year, managers must ensure the staff member completes a new Conflict of Interest and Commitment Disclosure form in Workday.

Employee
● Staff members must become familiar with and adhere to the University's Conflict of Interest and Commitment Policy and its related guidelines.
● Staff members must complete the Conflict of Interest and Commitment Disclosure form annually in Workday, whether there is a potential, actual, or perceived conflict or not.
● Staff members must ensure the annual Conflict of Interest and Commitment Disclosure form is completed accurately.
● Staff members must disclose any new conflicts that arise during the year and submit a new Conflict of Interest and Commitment Disclosure form in Workday.
 

Resources for Completing the Conflict of Interest and Commitment Disclosure Form


Conflict of Interest and Commitment Policy

Conflict of Interest and Commitment Management Plans

Disclosure Guidelines

Frequently Asked Questions: Conflict of Interest and Commitment

Preview Conflict of Interest and Commitment Annual Disclosure Questions

Workday Job Aid