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.
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.
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.
Will I have to re-enter the same information again next year?
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.
How do I edit a disclosure that has already been cleared?
You can edit a disclosure that has already been cleared during the annual Conflict of Interest Disclosure Campaign. However, if you need to edit or update a disclosure outside of that timeframe, please contact the office of Compliance, Ethics, and Regulatory Affairs at 205-348-2334 or coicompliance@ua.edu