Conflict of Interest and Commitment Process

Introduction

Click here for instructions to launch the Conflict of Interest and Commitment Process in Workday.

The Conflict of Interest and Commitment process is launched annually via Workday.  All staff members (regular and fixed term) are required to complete a Conflict of Interest and Commitment Disclosure form annually as a condition of employment. Please note that seasonal and intermittent staff are excluded from the annual disclosure process, but they are still subject to the Conflict of Interest and Commitment Policy. In addition, staff members are required to complete a new Conflict of Interest and Commitment Disclosure form during the year to disclose potential, actual, or perceived conflicts. The full disclosure of  potential, actual, or perceived conflicts of interest is necessary to determine whether the activity is permitted.

All members of the Brown Community are responsible for complying with the University's Conflict of Interest and Commitment Policy and its related guidelines, in addition to disclosing potential, actual, or perceived conflicts as they arise to their supervisor or assigned senior administrator. Failure to comply will be deemed a failure to meet one’s obligations for which sanctions, up to and including suspension without pay or dismissal, may be imposed.

Roles & Responsibilities

Manager

  • Managers must ensure all staff members complete the Conflict of Interest and Commitment Disclosure form in Workday.
  • Once submitted, managers 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, ensure the staff member completes a new Conflict of Interest and Commitment Disclosure form in Workday.

Employee

  • Staff members must read and understand 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.

Disclosure Period

The annual disclosure period is January to December of the prior year.  Financial information (e.g., additional compensation, ownership interest, gifts, etc.) 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 in the year in which they occur.

Annual Reporting Process

Under Resources below, refer to the Conflict of Interest and Commitment Guidelines when completing the following steps in the process:

  1. In February, all staff members receive an email with a link to instructions for launching the Conflict of Interest and Commitment process in Workday.
  2. Staff answer nine Yes/No questions on the Conflict of Interest and Commitment Disclosure form ("yes" answers require additional information); staff members should consult with their manager to determine if the conflict is substantial enough to require a management plan.
  3. Managers are responsible for reviewing all disclosure forms and determining whether the conflict is substantial enough to require a management plan. Managers work with their staff members and senior administrator to develop a management plan using information from the Conflict of Interest and Commitment Management Plan as a guide.
  4. 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; Institutional 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 in March.   

Disclosure Updates

Staff members are required to complete a new disclosure form during the year in which a new 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.

Resources for Completing the Conflict of Interest and Commitment Disclosure Form 

Administrative Policy 20.065, Conflict of Interest and Commitment 

Conflict of Interest and Commitment Frequently Asked Questions

Conflict of Interest and Commitment Guidelines

Conflict of Interest and Commitment Job Aid

Conflict of Interest and Commitment Management Plans

Preview: Conflict of Interest and Commitment Annual Disclosure Form Questions in Workday

Click here for additional related policies and information.