{"id":2610,"date":"2026-09-04T22:17:34","date_gmt":"2026-09-04T22:17:34","guid":{"rendered":"https:\/\/stagewp.westernu.edu\/hr\/?page_id=2610"},"modified":"2026-09-04T22:32:12","modified_gmt":"2026-09-04T22:32:12","slug":"conflict-of-interest-faqs","status":"publish","type":"page","link":"https:\/\/www.westernu.edu\/hr\/conflict-of-interest-faqs\/","title":{"rendered":"Conflict of Interest (COI) FAQs"},"content":{"rendered":"<section class=\"hero-secondary\">\n  <div class=\"relative bg-black\">\n                <img decoding=\"async\" class=\"adhere object-cover\" src=\"\/media\/hr\/images\/campus03.jpg\" srcset=\"\" sizes=\"100vw\" alt=\"a bench on a sidewalk next to a building.\">\n      <div class=\"adhere gradient-overlay\"><\/div>\n        <div class=\"relative container pt-56 md:pt-112 pb-144 md:pb-192\">\n      <div class=\"md:flex md:justify-between px-12\">\n        <div class=\"sm:w-8\/12 md:w-6\/12 xl:w-5\/12 px-12\">\n                      <div class=\"mb-20\">\n              <div class=\"block font-sans font-bold text-14 text-white leading-130\">\n  <span class=\"inline-block\">\n    <a href=\"\/\" class=\"block hover:underline\">WesternU<\/a>\n  <\/span>\n      <span class=\"inline-block mx-6\">\/<\/span>\n          <a href=\"https:\/\/www.westernu.edu\/hr\" class=\"inline-block hover:underline\">Office of Human Resources<\/a>\n          <span class=\"inline-block mx-6\">\/<\/span>\n    <span class=\"inline-block\">Conflict of Interest (COI) FAQs<\/span>\n  <\/div>            <\/div>\n                                        <h1 class=\"t-h1-sans  text-white\">Conflict of Interest (COI) FAQs<\/h1>\n        <\/div>\n              <\/div>\n    <\/div>\n  <\/div>\n<\/section>\n\n\n<section class=\"relative my-48 md:my-72\">\n  <div class=\"container\">\n    <div class=\"lg:flex px-12 lg:justify-center\">\n      \n      \n                  \n      \n      \n      <div class=\"w-full px-24 wysiwyg-content\">\n        <h2>What is a Conflict of Interest (COI)?<\/h2>\n<p>All University employees are required to disclose and explain any relationship, Close Relation, Outside Activities, Significant Interest, and\/or financial activity that creates an actual, perceived, or potential Conflict of Interest (inclusive of Conflict of Commitment). Prompt disclosure supports transparency and allows for effective management or mitigation of potential conflicts, ensuring continued focus on WesternU\u2019s mission. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment Policy<\/a><\/p>\n<h2>What are some examples of potential or actual conflict of interest?<\/h2>\n<p>Here are a few examples of personal, financial, and professional conflicts, please note that the examples are not exhaustive:<\/p>\n<p><em>Personal\/Relational<\/em> <em>Conflicts<\/em><\/p>\n<ul>\n<li>A faculty member serves on a promotion and tenure (P&amp;T) or awards committee reviewing a candidate with whom they have a romantic, familial, or close personal<\/li>\n<li>A supervisor directly manages, evaluates, or makes compensation decisions for their spouse, partner, relative, or close friend.<\/li>\n<li>A staff member participates in a hiring search where a close friend or family member is an applicant.<\/li>\n<li>A faculty member teaches, grades, or advises a student with whom they have a personal or family relationship.<\/li>\n<\/ul>\n<p><em>Financial<\/em> <em>Conflicts<\/em><\/p>\n<ul>\n<li>A faculty member responsible for organizing a university event seeks to hire a family member&#8217;s business (e.g., a catering company) as the vendor.<\/li>\n<li>A faculty member owns or holds equity in a private company and directs university research funds, purchases, or student labor toward that company.<\/li>\n<li>A staff member with purchasing authority selects a vendor in which they or a family member has a financial interest, or accepts gifts or hospitality from vendors seeking university<\/li>\n<li>An employee holds outside consulting arrangements with a company that also sponsors their university research.<\/li>\n<\/ul>\n<p><em>Professional\/Institutional<\/em> <em>Conflicts<\/em><\/p>\n<ul>\n<li>A faculty member sits on a committee and participates in the review or decision-making of a matter in which they have a direct personal or financial stake \u2014 for example, reviewing a grant proposal from a close collaborator or competitor, or voting on a policy that would financially benefit their own center or program.<\/li>\n<li>A faculty member uses university resources, facilities, or staff time to support outside consulting or a private<\/li>\n<li>A staff member uses confidential information gained through their university role to benefit themselves or an outside organization.<\/li>\n<\/ul>\n<h2>When is the annual disclosure period?<\/h2>\n<p>July 1st through June 30th including any time that a conflict of interest arises. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment Policy<\/a><\/p>\n<h2>Do I need to update my disclosure if my circumstances change mid-year or during the disclosure period?<\/h2>\n<p>Yes. In addition to completing the required annual certification, all University employees have a continuing and affirmative obligation to promptly disclose any new, potential, perceived, or actual conflicts of interest or commitment that arise after submission of the annual certification and before the next reporting cycle. This includes material changes to previously disclosed interests or activities that may alter the nature or extent of the conflict. Disclosures must be made as soon as the conflict becomes known, regardless of the employee\u2019s assessment of its significance or manageability. Failure to timely disclose new or evolving conflicts may constitute a violation of this policy. Supervisors, Department Chairs, and Deans who become aware of a reportable conflict involving an employee under their supervision must instruct the University employee to disclose the conflict in accordance with the procedures outlined below. All approved conflict disclosures are subject to ongoing review. Employees and faculty members are required to immediately notify their supervisor, department chair, Dean, or the Office of Human Resources of any changes to previously disclosed activities covered by this policy. University administrators and Deans may establish, within their areas of responsibility, mandatory periodic conformance and compliance reporting procedures for their respective employees.<\/p>\n<h2>Who does this apply to?<\/h2>\n<p>The policy applies to <u>ALL<\/u> Employees (no matter your capacity or FTE) and Independent Contractors and Vendors doing Business with WesternU.<\/p>\n<h2>How do I access the form?<\/h2>\n<p>The Conflict of Interest and Commitment Form can be accessed: <a href=\"https:\/\/support.westernu.edu\/TDClient\/1848\/Portal\/Requests\/Service\/56597\/Conflict-of-Interest-and-Commitment-Disclosure-Form\">HERE<\/a><\/p>\n<h2>Why do I have to disclose potential conflicts of interest?<\/h2>\n<p>Disclosure is required by WesternU institutional policy. The University&#8217;s policy has long required employees to disclose and obtain approval for conflicts of interest. The revised policy strengthens this longstanding requirement by centralizing the disclosure process, clarifying the scope of the policy, and expanding it to include other external activities that could give rise to conflicts of interest or conflicts of commitment. Disclosure allows the University to identify and manage potential conflicts appropriately, protecting both the employee and the institution.<\/p>\n<h2>What will happen if a conflict of interest is identified?<\/h2>\n<p>If a conflict is identified, WesternU will develop a management plan to mitigate the conflict. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment <\/a><a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Policy<\/a><\/p>\n<h2>Are there certain types of conflicts that are prohibited?<\/h2>\n<p><u>Prohibited Conflicts of Interest<\/u>: As a general rule, University employees refrain from engaging in any of the following activities unless they have been fully disclosed and receive explicit approval from the employee\u2019s supervisor, department chair or Dean, and the Office of Human Resources:<\/p>\n<ul>\n<li>Participating in any University Decision that directly impacts (positively or negatively) a University student, University employee, or independent contractor with whom the University employee is a Close Relation<\/li>\n<li>Pursuing Outside Activities that compromise the University employee\u2019s ability to act in the University\u2019s best interests or that demand a level of time and attention that detracts from their University duties (see Conflict of Commitment for additional details).<\/li>\n<li>Taking advantage of a business opportunity discovered through University employment, especially when that opportunity could reasonably be considered one that belongs to the University.<\/li>\n<\/ul>\n<ul>\n<li>Utilizing University equipment, materials, or other resources for purposes outside the scope of official University responsibilities, such as for financial benefit, personal business ventures, or Personal Gain, unless written advance approval is obtained from the Provost (for faculty), the Vice President for Human Resources (for all other employees), or their designated representatives.<\/li>\n<li>Taking any action that could be interpreted as a University endorsement (e.g., of a product, service, political position, or private enterprise) without prior written authorization from the Provost, President, or their designees.<\/li>\n<\/ul>\n<p><strong><u>Conflict of Commitment (COC)<\/u><\/strong><\/p>\n<h2>What is a Conflict of Commitment (COC)?<\/h2>\n<p>The University recognizes that University Employees and Faculty members may seek or hold additional jobs or be involved in business and community relationships outside of their employment with the University that can enhance their skills and advance the University\u2019s mission. Such activities are encouraged within the limits set by this policy, which ensure that University responsibilities remain the priority. Prior to accepting outside employment or other outside engagements, University employees should carefully consider the demands, responsibilities, and time requirements of their Outside Activities, and its effect on their University employment. <strong>University employees must disclose and obtain prior approval from their respective Supervisor and the Office of Human Resources for any Outside Activities to avoid Conflicts of Interest or Conflict of Commitment.<\/strong><\/p>\n<p>University employees may not participate in Outside Activities that require regular or significant absences during work obligations\/work schedule or when University duties are expected to be performed, or which may compete with University interests, interfere with job performance and\/or responsibilities, or involve extensive time commitments that conflict with their availability to perform work for the University. This provision does not limit an employee\u2019s rights to request or take approved leave in accordance with applicable University leave policies of a faculty sabbatical leave. If the Outside Activities cause or contribute to job-related problems and\/or performance-related issues, the University employee may be required to discontinue the Outside Activities and\/or may be subject to discipline under existing University policies.<\/p>\n<p>These activities may be compensated or not, including but not limited to, additional full or part-time employment, holding multiple concurrent jobs, consulting, or other contracting work, or serving on external boards that involve a commitment of time that may interfere with the Individuals\u2019 fulfillment of their WesternU responsibilities. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment Policy<\/a><\/p>\n<h2>Why do I have to disclose external activities?<\/h2>\n<p>You are required to disclose certain external activities to help ensure that your outside commitments do not interfere with your responsibilities to the University. The purpose of the Conflict of Interest and Commitment Policy is not to prevent employees from engaging in outside employment or professional activities, but rather to ensure that those activities do not create an actual or perceived conflict with your obligations to WesternU.<\/p>\n<h2>What external activities am I required to disclose?<\/h2>\n<p>External activities include, but are not limited to, whether paid or unpaid:<\/p>\n<ul>\n<li>additional outside employment (I.e. full or part-time employment (including self-employment))<\/li>\n<li>consulting or other contracting work<\/li>\n<li>serving on external or voluntary boards,<\/li>\n<li>business ownership<\/li>\n<\/ul>\n<h2>Do I have to disclose unpaid external activities?<\/h2>\n<p>University employees must disclose and obtain prior approval from their respective Supervisor and the Office of Human Resources for any Outside Activities to avoid Conflicts of Interest or Conflict of Commitment.<\/p>\n<h2>What happens if I do not comply with disclosure requirements?<\/h2>\n<p>As noted in the policy, individuals who fail to comply with Policy \u2014 including failure to disclose or submission of an erroneous, misleading, or incomplete disclosure as required by this Policy, or failure to comply with a Conflict Management Plan, may be subject to disciplinary action, up to and including termination of employment. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment Policy<\/a><\/p>\n<h2>Where is the Policy located?<\/h2>\n<p>The Conflict of Interest and Commitment Policy can be found: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">HERE<\/a><\/p>\n<h2>Can I use University Resources for personal use?<\/h2>\n<p>University employees are prohibited from using University resources for personal use, except when such personal use is specifically authorized by written University policy applicable to the University as a whole. All work and services performed by university employees (while being compensated by the University) shall be solely to advance University interests. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest<\/a> <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">and Commitment Policy<\/a><\/p>\n<h2>Can I use University information for personal use?<\/h2>\n<p>University employees are prohibited from using any Confidential or Privileged information for Personal Gain or other unauthorized purposes, confidential or privileged information acquired in connection with the individual&#8217;s University supported activities, as this activity is determined to be a prohibited Conflict of Interest. Confidential or privileged information is non-public information pertaining to the operation of any part of the University including, but not limited to, documents so designated, medical, personnel, or security records of individuals; anticipated material requirements or price actions; knowledge of possible new sites for University-supported operations; knowledge of forthcoming programs or of selections of contractors or subcontractors in advance of official announcements; and knowledge of investment decisions. Questions about confidential information may be referred to the University General Counsel. For further information, please review the policy: <a href=\"https:\/\/westernu.sharepoint.com\/sites\/PolicySite\/Approved%20Documents\/Forms\/AllItems.aspx?id=%2Fsites%2FPolicySite%2FApproved%20Documents%2FConflict%20of%20Interest%20and%20Commitment%2Epdf&amp;parent=%2Fsites%2FPolicySite%2FApproved%20Documents\">Conflict of Interest and Commitment Policy<\/a><\/p>\n<h2>What if I have other questions or need help?<\/h2>\n<p>You can email us at <a href=\"mailto:COI@westernu.edu\">COI@westernu.edu<\/a> or at <a href=\"mailto:EmployeeRelations@westernu.edu\">EmployeeRelations@westernu.edu<\/a>.<\/p>\n\n      <\/div>\n    <\/div>\n  <\/div>\n<\/section>\n","protected":false},"excerpt":{"rendered":"","protected":false},"author":5,"featured_media":0,"parent":0,"menu_order":13,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":"","_links_to":"","_links_to_target":""},"class_list":["post-2610","page","type-page","status-publish","hentry"],"acf":[],"aioseo_notices":[],"aioseo_head":"\n\t\t<!-- All in One SEO Pro 4.9.10 - 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