Conflicts of Commitment Policy | University Policy Manual

1.Purpose

Consistent with the University of North Carolina Greensboro’s research, teaching, and public service missions, the University encourages professional activities that promote intellectual exchange, enhance professional development, spark innovation, build capacity, and address pressing challenges both within our immediate and larger communities. Faculty members may achieve these goals through traditional academic pursuits, such as teaching and publication in scholarly venues. In addition, and increasingly, faculty and professional staff may add value to the University and the community by engaging in relationships with private industry and the nonprofit sector. Consulting, service on advisory boards, translational research activities, and commercialization of new technologies provide opportunities for faculty and professional staff to meaningfully engage with for-profit and nonprofit organizations, building capacity both for the individual, the University, and the larger community.

At the same time, the trust of the larger public that is core to our identity as a public institution, and the expectations of scholarly integrity and objectivity that are core to our identity as an academic institution, must be kept central. Relationships between faculty, staff, and outside entities can engender circumstances where primary obligations to the University can become entangled with secondary opportunities that introduce the potential for, or appearance of, conflicts of commitment when carrying out University responsibilities. This can be most problematic when individuals stand to personally gain from particular choices.

Recognizing that upholding the trust vested in the University and its individual faculty and professional staff members is paramount for the continuing livelihood of the institution, this policy establishes UNC Greensboro’s process for disclosing, identifying, evaluating, and managing Conflicts of Commitment. The requirement that an individual’s external professional activities be disclosed and evaluated does not reflect the integrity of the individual. Rather, as members of a community that values intellectual discourse and transparency, we acknowledge that peer review is an important part of maintaining objectivity and credibility. Further, the presence of a conflict does not imply that a situation is unethical or impermissible. Instead, it means that the situation must be carefully evaluated, and in some cases, managed to avoid perceptions of bias.

2.Authority

This policy defines UNC Greensboro’s implementation of the UNC System Policy on Conflict of Interest and Commitment (UNC Policy Manual 300.2.2), and any associated regulations as currently adopted, and as may be promulgated in the future. To the extent that any future updates to UNC System policies conflict with UNC Greensboro’s policies, the UNC System policies shall control.

3.Scope

This policy applies to all Covered Individuals. The analysis required by this policy applies even if the Covered Individual is on a leave of absence.

4.Definitions

4.1Conflict of Commitment:

Conflict of Commitment relates to situations in which a Covered Individual engages in activities external to the University, or assumes commitments external to the University that compromise, may appear to compromise, or have the potential to compromise their ability to fulfill their University Duties.

4.2Covered Individual:

Any faculty employee, Exempt Professional Staff (EPS), Senior Academic and Administrative Officer (SAAO), or any individual, regardless of employment type or status, supported by a sponsored research award, who is designated as senior/key person for the project and is responsible for the design, conduct, reporting, or funding of such research. The definition of Covered Individual may be expanded for a particular sponsored project when required by the federal award terms. Affected individuals will be notified of their inclusion and shall be considered Covered Individuals only for the period of time they participate in the applicable award.

4.2.1Covered Individual’s Immediate Family:

Covered Individual’s Immediate Family is defined as spouse (including a person to whom one is married or with whom one lives together as a domestic partner), children, parents, and siblings.

4.3External Professional Activities:

External Professional Activities is defined as any activity, paid or unpaid, that:

Is not included within one’s University Duties;
Is performed for any entity, public or private, other than UNC Greensboro; and
Is based upon the professional knowledge, experience, and abilities for which UNC Greensboro employs the Covered Individual.

4.4Inappropriate Use of University Resources:

Any use of University-funded or supported resources, including but not limited to University facilities, administrative offices, software, work product, research results, materials, property records, or information developed with University funding or other University support, except as otherwise allowed by University policy, for any purpose other than the Covered Individual’s University Duties. A Covered Individual engaged in external professional activities may not use any such University-funded or supported resources in the course and conduct of externally compensated activities, except as allowed by University policies (for instance, the Acceptable Use of Computing and Electronic Resources, and the Facility Use Policy). This includes the receipt of remuneration from both the University and an external entity for the same activity (i.e., travel reimbursement). Under no circumstances may a Covered Individual use the services of another University employee during that employee’s University work hours to advance the Covered Individual’s personal, non-University related interests.

4.5Management Plan:

The formal documentation described in the University’s Procedures for the Disclosure, Review, and Management of Activities Involving Potential Conflicts of Interest and Commitment detailing how a potential Conflict of Commitment should be managed or reduced.

4.6University Duties:

The assigned University Employment Responsibilities, generally teaching, scholarship, research, institutional service, administrative responsibilities, and other assigned employment duties. They are divided into Primary and Secondary Duties.

4.6.1Primary Duties

Primary Duties consist of assigned teaching, scholarship, research, institutional service requirements, administrative duties, and other assigned employment duties.

4.6.2Secondary Duties

Secondary Duties are professional affiliations and activities traditionally undertaken by Covered Individuals that are in addition to Primary Duties and that advance the mission of the University. Secondary Duties may or may not include the receipt of honoraria, remuneration or the reimbursement of expenses (see additional regulations, UNC Policy Manual, 300.2.2.1 [R]), and include membership in and service to professional associations and learned societies; membership on professional review or advisory panels; presentation of lectures, papers, concerts or exhibits; participation in seminars and conferences; reviewing or editing scholarly publications and books; and service to accreditation bodies. These activities, which demonstrate active participation in a profession, are encouraged and often valued in promotion and tenure and other performance reviews, provided they do not conflict or interfere with the timely and effective performance of the Covered Individual’s Primary Duties or with related University policies.

5.Conflicts of Commitment and External Professional Activities

5.1Conflicts of Commitment

Conflicts of Commitment relate to situations in which a Covered Individual engages in activities external to the University, or assumes commitments external to the University that compromise, may appear to compromise, or have the potential to compromise their ability to fulfill their University Duties.

Covered Individuals who engage in external activities not involving University Duty-related professional knowledge, experience, and abilities are not required to follow the advance disclosure and approval requirements of this policy for such external activities.

However, Covered Individuals and their supervisors shall ensure that any such activities do not result in the neglect of their University Duties, create unmanageable Conflicts of Commitment in accordance with this policy, involve Inappropriate Use of University Resources, inappropriate use of the University name, or include claims of University responsibility for the activity.

5.2External Professional Activities

Participation of Covered Individuals in External Professional Activities is an important characteristic of academic employment that often leads to significant societal benefits, including economic development through technology transfer. However, External Professional Activities are to be undertaken only if they do not:

Create a Conflict of Commitment by interfering with the obligation of the individual to carry out all University Duties in a timely and effective manner;
Create an unmanageable Conflict of Interest;
Involve Inappropriate Use of University Resources;
Make any use of the name or marks of the University for any purpose other than professional identification; or
Claim, explicitly or implicitly, any institutional responsibility for the conduct or outcome of the External Professional Activities.

5.3Additional Special Circumstances

Additional circumstances sometimes associated with External Professional Activities may require special consideration. These include:

In instances when state-reimbursed travel, work time, or resources are used or when the activity can be construed as related to the Covered Individual’s University Duties on behalf of the state, the Covered Individual shall not receive any financial consideration, including an honorarium.
External Professional Activities performed for another UNC Constituent Institution or a state agency must also comply with applicable state policies governing dual employment and compensation.
The UNC Board of Governors has also established rules for monitoring and regulating the involvement of University employees in political candidacy and office-holding that could interfere with full-time commitment to University Duties. Please refer to UNC Policy Manual for additional and specific policy details.

5.4Policy on External Professional Activities

When reviewing a matter for Conflict of Commitment, Covered Individuals must also analyze, apply, and comply with the University’s Policy on External Professional Activities as well as UNC System Regulation on External Professional Activities (UNC Policy Manual 300.2.2.1[R]), which contain provisions established to monitor possible conflicts.

6.Compliance

It is the policy of the University that activities that may result in actual or perceived Conflicts of Commitment related to the conduct of University Duties must be disclosed for review, and any potential Conflict of Commitment must be managed or eliminated prior to engaging in the activity.

6.1Responsibilities of Covered Individuals

Covered Individuals have several responsibilities for understanding, disclosing, and managing Conflicts of Commitment pursuant to federal, state, local, UNC System, and UNC Greensboro regulations.

All Covered Individuals who will play a role in the design, conduct, or reporting of an externally funded project must complete Conflicts of Interest Collaborative Institutional Training Initiative (CITI training) at least once every four years.
Covered Individuals must disclose activities outside the University that could be perceived to introduce bias into the conduct of their University Duties. Covered Individuals must disclose such activities at the following points:
- When submitting a Notice of Intent of External Professional Activities;
- When prompted to complete the University’s annual disclosure process; and
- Within thirty (30) calendar days of the acquisition of a new financial or personal interest that might entail a possible Conflict of Commitment, Covered Individuals must supplement the prior annual submission of the Conflict of Interest and Commitment questionnaire.

Continued transparency through the review and management of potential Conflicts of Commitment is expected of Covered Individuals. For situations in which a Management Plan is put into place, Covered Individuals are expected to adhere to the Management Plan and be active partners with the University in ensuring that they carry out their University Duties fully and with objectivity and integrity.

6.2University Responsibilities

The University has several responsibilities regarding the promotion of objectivity and ensuring that the institution and its Covered Individuals comply with federal, state, and local regulations related to situations involving actual or perceived Conflicts of Commitment.

The University will maintain an up-to-date written policy and process for identifying and managing Conflicts of Commitment.
The University will keep the campus community informed of the policies and procedures related to Conflicts of Commitment and will make every effort to provide accessible and timely professional development related to the topic.
The University will monitor and enforce implementation of the Conflicts of Commitment policies and procedures.

6.3University Reporting

The University will comply with all applicable regulations to make any required reports and disclosures available to the public.

6.4Relation to Other Policies, Law, and Regulation

Existing regulations at the federal, state, local, and UNC System levels, may further govern the definition, disclosure, review, and management of activities that may engender Conflicts of Commitment.

7.Confidentiality

Disclosure of activities and information related to External Professional Activities and Conflicts of Commitment may be contained within confidential personnel records pursuant to applicable state law (see North Carolina General Statutes §126-22).

8.Enforcement

The Chancellor has delegated authority for enforcement of this policy to the Provost and Executive Vice Chancellor when faculty are involved, and to the Provost and Executive Vice Chancellor to coordinate the review of all other Conflicts of Commitment with the appropriate University officials, including but not limited to the Associate Vice Chancellor for Human Resources and the Vice Chancellor for the division within which a Covered Individual is employed.

Any violation of this policy may be considered “misconduct” pursuant to UNC Greensboro’s employment policies. It should be noted that violation of this policy may also implicate violations of related federal or state statutes or regulations that could result in penalties outside the auspices of the University.

9.Related Law, Policies, and Regulations

9.1State of North Carolina

North Carolina General Statute on Public Officers or Employees Benefiting from Public Contracts; Exceptions (N.C.G.S. 14-234)
North Carolina State Government Ethics Act (N.C.G.S. 138A)

9.2UNC System

9.3UNC Greensboro

10.Reporting and Contact Information

Responsible Executive: Provost and Executive Vice Chancellor (for faculty)

Conflicts of Commitment Policy Administrator: Director of Research Compliance and Integrity email: ori@uncg.edu

Revisions

Revision Date	Revision Summary
02/09/1996	Amended
02/24/2012	Amended
10/09/2014	Amended
03/12/2018	Revised
10/28/2024	Revised to conform with updates to Board of Governors' policy
05/11/2026	Revised