Management of a Conflict of Interest in the Workplace

  • If it is determined that a disclosed external activity or interest poses, or appears to pose, a conflict of interest in the workplace, the respective Associate Dean for Faculty or the Senior HR Representative will work with the employee’s supervisor and/or DEO to develop a written management plan using the Management Plan Template.
  • Management plan actions may include:  nothing beyond documentation of disclosure, strategies to eliminate the conflictual elements of the activity, and/or prohibition of the activity.
  • The proposed plan will be forwarded to the respective collegiate dean or vice-president for review and approval.  A copy of this management plan shall be shared with the appropriate parties and maintained in the employee's personnel file.
  • An employee’s conflict of interest disclosures and any existing management plans will be reviewed at least annually, or as needed, by the central administrative office, the employee’s employing unit, and the respective Dean or Vice President. 

Management of a Conflict of Commitment (Faculty Effort)

  • If a DEO or equivalent determines that engaging in an external activity poses a conflict of commitment, the DEO or equivalent will work with the faculty member to develop a written Management Plan Template below.
  • Management plan actions will vary based on the situation and may include:  requiring nothing beyond documentation of disclosure, arrangements to cover all university responsibilities during his or her absence, strategies to eliminate the conflictual elements of the activity, and/or prohibition of the activity.
  • A management strategy for a conflict of commitment shall not include any reduction in an employee's salary and shall not otherwise take into account payments received by an employee for outside activities, unless the management strategy also includes a formal reduction in employee effort or a leave of absence from the University.
  • No account of disclosures or management plans shall be taken into consideration at a later date when setting the annual salary of an employee, including any payments received by an employee from outside sources that are disclosed in connection with the employee’s disclosure of any conflict of commitment or interest.
  • A copy of management plans related to Conflicts of Commitment shall be maintained in the employee's personnel file. 

Additional Guidance

Required Elements of a Written Management Plan

In support of effective and consistent implementation of management plans, all written Management Plans should include the following elements:

  1. Employee Information
    Employee name, University of Iowa position, and department or unit.
  2. Description of the Disclosed Activity or Interest
    A brief description of the outside activity, financial interest, or relationship that has been identified as creating an actual, potential, or perceived conflict of commitment and/or conflict of interest in the workplace, as documented through the disclosure review process.
  3. Management Plan Actions
    Specific actions or conditions established to manage, mitigate, or eliminate the identified conflict. Management actions should be tailored to the circumstances and may include documentation only, modification of duties, oversight mechanisms, limitations on activities, or prohibition of the activity, as appropriate. Relevant institutional policies and guidance should be consulted when determining management actions. COI-W Review and Management Considerations
  4. Statement of Understanding
    A statement confirming that the employee has reviewed the Management Plan, understands the expectations and conditions outlined, and agrees to comply with the plan.
  5. Administrative Approval
    Approval by the Departmental Executive Officer (DEO) or Supervisor, and by either the Senior HR Leadership Representative (for staff) or the Associate Dean for Faculty (for faculty), as applicable.
  6. Employee Acknowledgment
    Employee signature and date indicating awareness of and agreement with the Management Plan.
  7. Filing and Monitoring Notes
    Documentation of where the Management Plan is maintained, the effective date of the plan, and expectations for review or reassessment, including annual or situational review as required.

Reviewer Responsibilities

To support consistent review and oversight, the following responsibilities apply to the Senior HR Leadership Representative or Associate Dean for Faculty involved in management plan development:

  1. Review referral materials provided by the Central Office, including the Disclosure Report and any associated comments.
  2. Conduct an additional review to identify any relevant contextual information at the unit or collegiate level that may inform management strategies.
  3. For disclosures categorized as requiring additional oversight ("Yellow" or "Red"), consult applicable management considerations and institutional policies when determining whether a Management Plan is appropriate.
  4. When a Management Plan is required, collaborate with the employee’s DEO/Supervisor to develop a written plan using the University’s Management Plan Template. Attach additional sheets, as needed. Consult with the relevant UI Policies and Resources for Managing Conflicts of Interest in the Workplace for UI policies that might pertain to the situation.
  5. Obtain all required approvals and provide copies of the finalized Management Plan to the employee and appropriate leadership.
  6. Ensure that a copy of the signed Management Plan is maintained in the employee’s ePersonnel file.
  7. Notify the Central Office that a Management Plan is on file and record the date of employee acknowledgment.

Resources