Conflict of Interest Program

Conflict of Interest Program


The UA Code of Ethical Conduct requires employees to be aware of the potential for Conflicts of Interest (COI) and/or Conflicts of Commitment (COC) and to exercise initiative to identify, review, and manage those conflicts appropriately.  All members of the University community are expected to comply with the Institutional Conflict of Interest/Conflict of Commitment Policy, as well as any other applicable policies or procedures adopted by UA.

Faculty and staff efforts to balance University responsibilities with external activities — such as consulting, public service, or pro bono work — can result in real or perceived conflicts regarding allocation of time and priorities. Additionally, personal relationships are valued and encouraged, but they can appear to influence decision-making in some circumstances.  University employees must proactively disclose, acknowledge, and address, as necessary, activities or relationships which may create or appear to create a conflict of interest or commitment. The failure to disclose situations that have the potential for or involve actual conflicts of interest or commitment may be unethical and/or illegal.

The primary goals of this program are to (a) provide assistance to the University committee in properly disclosing and managing real or perceived conflicts of interest or conflicts of commitment; (b) prevent an employee’s personal interest and activities from adversely influencing UA operations; (c) provide a framework for recognizing and managing employee conflicts; (d) provide education and guidance to help minimize even the appearance of conflicts; and (e) standardize university-wide procedures for the disclosure, review, management, and approval of actual or possible conflicts.

Frequently Asked Questions

What is a Conflict of Interest?

A conflict of interest on the part of a public employee exists when their private interests and their official job responsibilities are competing. A conflict of interest occurs when an employee or immediate family member has a personal interest in or receives a personal financial, economic, professional or personal gain or advantage of any kind from the employee’s position in a manner that may influence the employee’s judgment, compromise the employee’s ability to carry out University responsibilities or impair the University’s integrity.

What is a Conflict of Commitment?

A conflict of commitment is any outside employment or professional activity, paid or unpaid, by a public employee that could interfere with the performance of the employee’s primary institutional responsibilities.

Why do University Employees have to complete a Conflict of Interest/Conflict of Commitment Disclosure Form?

It is for the benefit and protection of the individual employee to disclose and manage any real or perceived conflicts in order to avoid violations of university policies, the Alabama State Ethics law, the Alabama nepotism law, and/or Federal regulations regarding sponsored research. Failure to complete and maintain an accurate disclosure form could lead to discipline based on University Policies. Failure to disclose research conflicts may also jeopardize the investigator’s and the University’s ability to receive federal grant funding.

Does the UA Conflict of Interest Disclosure replace the AL Statement of Economic Interests?

No. Completion of the Employee Conflict of Interest Disclosure fulfills the disclosure requirements of the University of Alabama Institutional Conflict of Interest/Conflict of Commitment Policy. Completion of the disclosure form will not fulfill the Alabama Ethics Commission’s requirement to file an annual Statement of Economic Interests (SEI). Employees who, by State Law, are required to complete the Alabama Ethics Commission’s Statement of Economic Interests are notified in February each year via email. Under Alabama law, notified employees who do not complete the SEI as required may be subject fines of up to $1,000 and a misdemeanor charge.

Why does the University have a Conflict of Interest/Conflict of Commitment Policy?

The University of Alabama is an institution of public trust. As public employees, University employees must be objective and impartial in acting and making decisions on behalf of the university in order to maintain public confidence in the integrity of our State institution. Disclosure of potential conflicts of interest and/or commitment are necessary to identify, manage, and/or eliminate these conflicts.

Do researchers also need to complete the Research Compliance Financial Conflict of Interest Disclosure?

At this time, the two disclosures address different interests. It will be necessary for researchers to complete multiple disclosures at this time.

Who must complete the Conflict of Interest/Conflict of Commitment Disclosure?

All employees of The University of Alabama as defined in the Conflict of Interest and Conflict of Commitment Policy.

How often do I have to complete the disclosure?

The online COI/C disclosure must be completed annually. You are also responsible for updating your disclosures within 30 days of any material change in the status of any real or perceived conflict, or of any triggering event that might create a new conflict (engaging in new consulting work, starting an outside business, your son/daughter starts working for the university, etc.). Newly hired employees must complete the COI/C disclosure within 30 days of their hire date.

What are triggering events that might create Conflicts of Interest/Conflicts of Commitment?

Common triggering events include but are not limited to:

  • Family member or close friend becomes a vendor for the University.
  • Getting married/divorced when your spouse is also an UA employee;
  • Starting a business or an outside job for which you receive compensation;
  • Being elected or appointed to a Board (Board of Directors, Advisory Board, etc.);
  • Family member (to 4th degree of consanguinity or affinity) being hired by the The University of Alabama (spouse, son/daughter, parent, sibling, grandchildren, grandparents, first cousin, niece/nephew, aunt/uncle);
  • Publishing a book and receiving income or royalties;
  • Outside consulting engagements;
  • Family member or close friend becomes a vendor for the University.
What types of Financial Interests do I have to disclose?

University employees must disclose:

  • Anything of value held or received by you personally or an immediate family member from an outside entity, including but not limited to dividends, paid authorship, ownership interest, stock or stock options, intellectual property rights, royalties or paid travel, that is related to your professional expertise or institutional responsibilities, or when the entity does or plans to do business with the university.
  • Any compensation from outside entities including companies and non-profit organizations, including foreign institutions and foreign governments.
  • Board positions (board of directors, advisory board, etc.) or leadership roles (CEO, owner, investor, partner, etc.) for any companies or organizations, including foreign, that are related to your professional expertise or institutional responsibilities, or when the entity does or plans to do business with the university.
  • Any professional undertaking which has the potential to improperly influence sponsored research or technology commercialization, including but not limited to an equity interest in or remuneration from a non-publicly traded entity, providing outside professional services, or state funded contracts.
Do I need to disclose my previous employer?

Not unless that entity is doing business with your department at The University of Alabama.

How long will it take to complete the online disclosure form?

It depends on what interests you have to disclose, if any. It should take only a few minutes to complete and certify. If you are a researcher and/or have several disclosures it may take up to 30-45 minutes.

Who decides if the information disclosed constitutes a conflict?

The information will be reviewed and evaluated by the office of Compliance, Ethics, and Regulatory Affairs together with the appropriate departments. The General Counsel, relevant deans, department chairs, and supervisors, as well as Human Resources, will be consulted as needed. The Conflicts of Interest Committee will have final review and oversight.

Is this different from the Research Conflict of Interest Disclosure that I have previously completed?

Yes and no. This new form includes the questions you may have previously answered as a research investigator, as well as additional questions on non-research financial or other interests. You will need to complete both disclosures.

What foreign affiliations do I need to disclose?

You must disclose any and all of the following affiliations. Many of these are common scholarly activities that do not pose any conflict of interest. However, some affiliations may pose serious national security concerns which is the reason for this inquiry. All foreign interests and activities should be disclosed.

  • Agreements or contracts
  • Research collaborations (including publications)
  • Talent recruitment programs or Friendship Awards
  • Positions, scientific appointments, and/or honors (including dean, guest, honorary, adjunct, or volunteer, with or without support)
  • Laboratories or office space outside the U.S.
  • Equipment, supplies, or employees
  • Gifts provided with terms or conditions
  • Financial support for laboratory personnel
  • Participation of student and visiting researchers supported by other sources of funding
  • Resources made available in support of and/or related to all of your professional R&D efforts
  • Financial interests
  • Intellectual property
  • UA-hosted visiting scholars
  • Travel or site visits paid for by a foreign source
  • Program evaluations paid for by a foreign source
  • Teaching or training engagements
  • Consulting engagements
  • Advising or mentoring engagements
  • Speaking engagements
  • Committees or boards
  • Contracts with or payments to a business owned by you
  • Other professional affiliations
How do I know if I have a management plan in place?

If you were contacted by the office of Compliance, Ethics, and Regulatory Affairs and worked with the appropriate area and your supervisor, signing an official UA drafted management plan will mean that your conflict has been managed. If you believe you have an existing management plan in place (verbal, or in writing) but have not signed an official UA drafted management plan, please contact CERA.

Can my Administrative Assistant complete the form for me?

No. You must log in to the portal with your mybama credentials to complete the disclosure form and certify that the information you provided is complete and accurate.

Will I have to re-enter the same information again next year?

No, you will have the ability to recertify your answers from the previous year in the system. You will only need to make edits or additions as needed. If the questionnaire has changed or additional questions are added, you may have to re-enter or add information.

Who should I contact if I have questions about completing the disclosure?

Please contact the office of Compliance, Ethics, and Regulatory Affairs at 205-348-2334 or coicompliance@ua.edu.

What should I do if I think there is a conflict at The University of Alabama that is not being managed?

Please send any concerns to the office of Compliance, Ethics, and Regulatory Affairs at 205-348-2334 or coicompliance@ua.edu.  You can also report any concerns anonymously to the Ethics and Fraud Hotline.