Conflict of Interest and Commitment Management Plans

If a management plan is required, staff should work with their manager to develop a plan that appropriately addresses the situation. Management plans should be submitted in Workday as part of the staff member’s Conflict of Interest and Commitment Disclosure form, whether during the annual process or as part of a disclosure made during the year. Submission of the form in Workday serves as the staff member’s electronic signature. 

A management plan is required when:

  • A familial relationship indicates a conflict of interest or commitment; the plan must identify how the family member whose position holds institutional seniority or authority will ensure they will not participate, influence, or shape the terms and conditions of employment or engagement of the less senior family member.
  • Outside employment or financial interests or public service is/are disclosed; the plan must ensure that the staff member’s Brown position is not being leveraged to enable these outside interests and that their duties to Brown remain the staff member’s priority. Management plans required to address these conflicts must also ensure Brown's resources, including its systems, equipment, and supplies will not be used in support of these outside commitments.
  • The staff member has been elected to a political office; the Political Activities Management Plan should be completed.

A management plan’s length and complexity depends on the nature and specifics of the conflict. At a minimum, it should state measures designed to mitigate any potential for a conflict of interest or commitment and include the following elements:

  1. Staff member’s name, title, and department
  2. Supervisor’s name and title
  3. A description of the staff member’s primary duties at Brown
  4. Specific identifying information concerning the person, business, or entity that is the basis for the conflict (e.g., name, business address, dates or hours of involvement with employee and/or Brown; relationship to Brown as a vendor, consultant, donor, student, parent, employee, business partner, or investment holding)
  5. A description of the relationship or situation that poses the conflict
  6. A description of the circumstances presenting a conflict between these interests, indicating if this conflict might happen (potential) or already exists (actual) or may be interpreted in a particular way (perceived) including examples of how an employee could act in favor of the non-Brown interest and the detriment or risk to Brown could be
  7. A description of the management and/or operational mechanisms and processes put in place to address the conflict and detailing how Brown’s interests will be protected.