Policy Number: C4.0

Policy Name: Individual Conflict of Interest and Commitment Policy

Introduction

This document states the university’s Individual Conflict of Interest and Commitment (ICIC) policy which is designed to protect the integrity of the university, its faculty, staff, students, and the scholarship process. 

The university encourages interactions with external entities that are beneficial to the professional standing of employees, the reputation and mission of the university, or serve the community or profession at large.  Such interactions may involve conflicts of interest or commitment.  In either case, however, the university expects employees to act with a high standard of integrity and ethical behavior and to avoid ethical, legal, financial, or other conflicts of interest or commitment, including even the appearance of a conflict, that might impede or compromise their university responsibilities or the mission of RIT.

Most potential, real, or perceived conflicts of interest and commitment which occur during the course of everyday academic life can be managed through disclosure and transparency. Unreported or unresolved conflicts, on the other hand, can disrupt or even potentially threaten the integrity of the individual and scholarship, research, instruction, evaluation, or administration of the university.

The university’s ICIC policy is designed to assist the free flow of knowledge and ideas and help ensure that public and university resources are used appropriately.  It mandates a practice of transparency and the management of conflicts of interest and commitment, whether potential, real, or perceived, to help ensure that RIT’s alliances with external entities further the aims of the individual and the university. 

Statement of Policy

The ICIC policy requires that all RIT faculty and staff self-disclose potential, real, or perceived conflicts of interest or commitment to their immediate supervisor.  If, after evaluation, a conflict is found to be significant or unacceptable, it shall be removed or managed as described in the operating procedures section of this policy.

Scope of Policy

Regular employees who are faculty and staff as defined in Policy E1.0-Employee Classification and Status are subject to the ICIC policy.  The ICIC policy may be extended to other groups, including student employees, visiting scholars and scientists, consultants, and vendors, at the discretion of the applicable immediate supervisor provided that the extension is stated in writing.

1. A Conflict of Interest exists whenever an employee’s personal, professional, commercial, or financial interests or activities outside of the university have the possibility—whether potential, real, or perceived—of a) compromising the employee’s judgment, b) biasing the nature or direction of scholarship, c) influencing the employee’s decision or behavior with respect to teaching, student affairs, promotions and appointments, use of university resources, interaction with human subjects, or other matters of interest to the university, or d) resulting in personal or a family member’sgain or advancement at the expense of the university.  It is important to keep in mind that an employee does not have to actually do anything wrong or improper for a conflict of interest to exist; the conflict exists by virtue of a relationship that could result in an undue influence on the employee’s professional judgment.


2. A Conflict of Commitment exists whenever an employee’s external commitments, relationships, or activities have the possibility—whether potential, real, or perceived—of interfering or competing with the university’s mission or with the employee’s ability or willingness to perform the full range of responsibilities associated with his or her position. 

Definition

Family Members. Family members - or family - are defined as parents, siblings, spouses, in-laws, domestic partners, children, and dependents.) 

Operating Procedures

To help ensure that RIT and its employees are not compromised by even the appearance of a conflict, employees must report outside activities to their immediate supervisors.  Outside activities are defined as relationships, commitments, or activities on the part of the employee or his/her family that might present or appear to present conflicts of interest or commitment with regard to the employee’s employment at RIT.  Outside activities may be uncompensated or they may involve financial or fiduciary obligations.  Outside activities should be reported upon employment, annually thereafter, and any time circumstances arise that may create conflicts of interest or commitment.  When a supervisor determines that conflicts of interest or commitment exist, the supervisor, in consultation with the employee, shall develop a plan to manage or eliminate the conflict. The disclosed outside activities of an employee and any resulting management plan must be approved by two levels of management, beginning with the immediate supervisor. Unresolved conflicts shall be referred to the Individual Conflict of Interest and Commitment Committee (ICIC Committee).  Decisions of the ICIC can be appealed to the provost or ranking divisional officer, whose determination is final.

“Procedures for the Implementation of the Conflict of Interest and Commitment Policy,” found at:  http://www.rit.edu/fa/grms/sites/rit.edu.fa.grms/files/docs/ConflictofInterestCommitmentProcedure9-11.pdf details the step-by-step course of action for annual and ad hoc disclosures, conflict management, oversight, sanctions, and appeals processes.

The ICIC shall be a standing RIT committee of eight (8) members selected by campus constituency groups as follows:   

• One member selected by the provost, serving a three-year term
• One member selected by the vice president for finance and administration, serving a three-year term
• Three members selected by Academic Senate, serving staggered three-year terms
• Three members selected by Staff Council, serving staggered three-year terms
• One ex-officio, non-voting member appointed by the vice president for research who shall provide administrative support to the committee.

The ICIC Committee shall deliver an annual report to Academic Senate, Staff Council, Institute Council, and to the chairman of the board of trustees.  Except to the extent necessary to carry out its functions, the committee’s proceedings shall be kept confidential by its members.

Responsible Office:  Global Risk Management Services and specifically RIT's chief risk and compliance officer

Effective Date: Approved prior to July 1975

Policy History:
Last revised May 9, 2007
Edited August, 2010
Edited October 10, 2011
Edited September 27, 2012 to correct URL and formatting