Conflict of Interest and Commitment

An African-American male student an older Caucasian male student, and several other students blurred out in the background, listening in a classroom.
 

Conflict of Interest
& Commitment

Submit your Conflict of Interest and Commitment Disclosure

If you need accommodations or assistance to complete your disclosure, please contact ConflictofInterest@rit.edu.

Overview

The integrity of RIT’s research, teaching and learning, outreach and public service activities is paramount. While the university encourages its faculty and staff to engage in relationships with business entities to further RIT’s mission, inherent in these relationships is the potential for professional judgment to be influenced by the existence of such relationships.

RIT is committed to ensuring that relationships between its faculty and staff and business entities are transparent, grounded in objectivity, and do not improperly influence any individuals’ professional judgment, the exercise of university responsibilities, or the performance of university-related activities. Thus, RIT has adopted a comprehensive Individual Conflict of Interest and Commitment (ICIC) policy that requires employees to disclose any potential, real, or perceived conflict.

Flowchart showing the 6 steps: Prevention, Discolsure, Assessment, Treatment, Recording & Reporting, and Monitoring.​

Employees must disclose conflicts of interest and commitment to protect the integrity of the university, its staff, faculty, students, and the scholarship process.

Employees must disclose any outside activities, financial interests, relationships, or other factors that create an actual, perceived, or potential conflict of interest or commitment. Disclosures must be made annually, or promptly after a change in circumstances that creates an actual, perceived, or potential conflict of interest or commitment.

Supervisors must review disclosures and determine whether a conflict of interest or commitment exists.

Upon determination that a conflict exists, supervisors must determine whether the conflict can be managed and, if so, supervisors must create a written Management Plan to treat the conflict. Management Plan templates, the ICIC Guidance document, and the Guidance for Management Plans (see below) can help with treatment strategies.

Disclosure Statements and Management Plans must be recorded and maintained in RIT's Conflict of Interest and Commitment software solution powered by Novelution, consistent with RIT's Record Retention Policy.

Supervisors must oversee compliance of their employees' Management Plans.

What To Disclose

Examples of situations that should be disclosed include:

  • Teaching at another university in the same field as the one you teach at RIT
  • Publishing a textbook you want students at RIT to purchase as part of a course you instruct
  • Participating in employment decisions that involve, or directly benefit or disadvantage your Immediate Family or Relative
  • Purchasing office supplies for your department from a company you or an Immediate Family or Relative owns, or from which the sale would benefit you or your Immediate Family or Relative
  • Selecting or working with your spouse's technology company as part of a new research project
  • Serving on the Board of Trustees of another institution of higher education
  • Submitting an invention disclosure or patent application with an outside entity if the entity is related to your field of work at RIT
  • Associating your name with the university in a way that suggests that your views or opinions represent the views of the university
  • Accepting a personal gift from a company competing to win business from RIT

Additionally, you are responsible for ensuring the any agreements you sign as part of your outside activities do not prohibit RIT's competitive involvement, or assert ownership of resulting work if the field of work is central to your role or responsibilities at RIT. If you have questions, consult with your immediate supervisor who should seek clarification from the university if needed.

What Not To Disclose

Examples of situations that generally do not require disclosure include:

  • Serving as an officer, board member, or volunteer in a professional, community-based, or a charitable organization
  • Receiving an honorarium as a one-time payment for a speaking engagement (unless arranged as part of a consulting arrangement, which should be disclosed)
  • Serving on a government panel or commission in which RIT has no business interest
  • Preparing an article for publication in a professional journal
  • Attending or presenting at an academic, professional, or technical conference

Employees who have questions about disclosing situations should talk with their immediate supervisor.

Resources

ICIC Guidance: FAQs, Management Plans, Sample Case Studies
ICIC Online Training (Links to RIT Talent Roadmap)
RIT COI Disclosure Platform Training Video
RIT COI Disclosure Platform Supervisor Training Video
RIT Conflict of Interest and Commitment Disclosure Platform Guide

Guidance for Management Plans

Black background with white text stating 'I have an actual Conflict of Interest'

actual conflict of interest

Black background with white text stating 'I have a potential or perceived Conflict of Interest'

potential conflict of interest

Black background with white text stating 'I have no actual or potential Conflict of Interest'

no conflicts of interest

 
  • RED
  • Actual Conflict of Interest
  • Management Plan required

An Outside Activity, Financial Interest, relationship, or other factor poses an actual conflict or is otherwise prohibited by policy. The conflict situation may go forward only after prior disclosure and only with an appropriate Management Plan in place to eliminate the conflict, safeguard against bias interfering with university-related decision-making, and provide mechanisms for continued oversight.

Red Designation Example:
Having a Financial Interest in an outside company that conducts business with RIT to which the Employee may be in a position to refer students or staff, resulting in personal gain. The Employee's Financial Interest in the outside entity may compromise, or have the appearance of compromising, the Employee's professional judgment in performing their university duties.

 
  • YELLOW
  • Potential or Perceived Conflict of Interest
  • Management Plan recommended

An Outside Activity, Financial Interest, relationship, or other factor poses a potential conflict or reasonable likelihood of the perception of one. Activities are likely permissible, but a Management Plan would decrease likelihood of a conflict developing now or in the future.

Yellow Designation Example:
It is unlikely that the Employee can influence a business decision pertaining to the Financial Interest, Outside Activity, relationship, or other factor, but the appearance of influence exists. A Management Plan is recommended.

No conflict exists, but it is reasonably possible that there will be a change in scenario in the future that will require a Management Plan (e.g., the Employee's Immediate Family Member is enrolled in an academic department but not currently assigned to the Employee's course at this time). Management Plan is not required at this time, but a Management Plan would be recommended and caution should be exercised.

 
  • GREEN
  • No Management Plan required
  • No Actual/Potential Conflict and Generally Permissible Activities

An Outside Activity, Financial Interest, relationship, or other factor does not appear to present an actual, potential, or perceived conflict. These disclosed situations may go forward after disclosure without a Management Plan.

Green Designation Example:
The Outside Activity is considered part of the Employee's position responsibilities (e.g., "academic activities" for faculty).

The Outside Activity, Financial Interest, relationship, or other factor will have no opportunity to compromise or appear to compromise the Employee's professional judgment (e.g., teaching, research, business decision-making).

Sample Management Plans

The following Management Plan Templates are provided for reference only. The templates are available in the conflict of interest disclosure platform, and are generated by supervisors once a conflict has been disclosed and requires management. 

Example General Management Plan
Example Relative Employed at RIT Management Plan
Example Relative Enrolled as a Student at RIT Management Plan

 

Conflicts for Researchers

All members of the RIT community, including faculty, students, and staff are expected to adhere to the highest ethical and professional standards when pursuing sponsored project activities.  Involvement with externally sponsored projects elevates these expectations to obligations because sponsors impose significant statutory and regulatory administrative requirements in connection with funding provided for these projects.  This document explains RIT's commitment to the legal and ethical administration of externally sponsored projects; provides administrative guidance to ensure compliance with the necessarily dynamic policies associated with such projects, and enables the Principal Investigators (PIs) and their operational units, Sponsored Research Services (SRS), and Sponsored Program Accounting (SPA) to facilitate the orderly administration of such externally sponsored projects. 

Read the Full Policy Document

 

Frequently Asked Questions

Conflicts of Interest exist whenever an individual’s personal, professional, commercial, or financial interests or activities outside of the Institute have the possibility—whether real or perceived—of: (1) compromising an employee’s judgment; (2) biasing the nature or direction of scholarship; (3) influencing an employee’s decision or behavior with respect to teaching and student affairs, promotions and appointments, uses of Institute resources, interactions with human subjects, or other matters of interest to the Institute; or (4) resulting in a personal or family member’s gain or advancement at the expense of the Institute. Family members are defined as spouses, parents, siblings, in-laws, children, domestic partners, and dependents.

Conflicts of Commitment exist whenever an employee’s external commitments, relationships, or activities have the possibility—whether real or perceived—of interfering or competing with the Institute’s mission, or with that individual’s ability or willingness to perform the full range of responsibilities associated with his or her position.

Conflicts of interest can compromise the quality of an employee’s decision-making. They can also negatively impact the perception of the university and the individual involved. The purpose of this policy is to ensure that the university operates in compliance with applicable and regulatory requirements, and that the reputation, name, and integrity of the university are not compromised. The fundamental principle guiding employees should not have, or appear to have, any personal or financial interests, relationships, or affiliations that conflict with the interests of the university. Most conflicts can be managed as long as they are disclosed. By disclosing conflicts, you and your supervisor can develop a management plan to mitigate the conflict, ensure integrity and independence in research and business decisions, and promote ethical use of university resources. 

When it is time for you to complete your annual COI disclosure, you will receive an email to complete the disclosure in the new platform.  The automated email will come from ritnovelution@rit.edu.  However, if you have a conflict situation arise prior to your annual disclosure due date, you can update your disclosure at any time by clicking the “Submit your Conflict of Interest and Commitment Disclosure” button at the top of this webpage.

Disclosure of service on non-profit organization boards is not usually required unless the organization does business with RIT or competes with RIT.

Your disclosure is sent to your immediate supervisor. Your supervisor will review your disclosure and determine whether a conflict exists. If your supervisor determines a conflict exists, you and your supervisor will work together to develop a Management Plan to eliminate or manage the conflict. If a conflict of interest or commitment cannot be resolved, supervisors should consult with the Office of Compliance and Ethics or, for researchers, Sponsored Research Services. Once you are in agreement, your second-level supervisor will have the opportunity to review and approve.

If you and your supervisor cannot agree on whether a conflict exists or agree on a conflict management plan, you or your supervisor may appeal the case to the Individual Conflict of Interest & Commitment Committee. The ICIC Committee will make a recommendation, with a final determination made by your divisional vice president.

If your supervisor determines that the disclosed activities or commitments constitute a real or perceived conflict of interest, then he/she will work with you to develop a plan of action to manage or eliminate the conflict. This conflict management plan will be submitted to the second-level supervisor for final approval.

If you and your supervisor cannot agree on the need for a conflict management plan, the second-level supervisor will refer your case to the Individual Conflict of Interest & Commitment Committee. The ICIC Committee will develop a conflict management plan for resolving the conflict.

Yes

All regular staff and faculty as those terms are defined in Policy E01.0 Employee Work Classification.

The RIT conflict of interest/commitment management process begins with disclosure to one’s immediate supervisor by submitting the Conflict of Interest and Commitment Questionnaire through Oracle employee self serve. After you complete the questionnaire, it will be automatically emailed to your supervisor. Your supervisor will review the questionnaire and determine whether a real, perceived, or potential conflict exists.

If your supervisor determines that there is no conflict, your disclosure is approved and forwarded to the second-level supervisor for review before final approval. If you have a conflict, you and your supervisor will develop a plan of action to manage or eliminate the conflict. This conflict management plan will be submitted to the second-level supervisor for approval.

If you and your supervisor cannot agree on a conflict management plan, the second-level supervisor will refer your case to the Individual Conflict of Interest & Commitment Committee.

The ICIC Committee will make a recommendation for resolving the conflict through a conflict management plan. The ICIC Committee’s decisions may be appealed to the Provost or ranking divisional officer, whose decision is final.

RIT defines immediate family and relatives in the Nepotism Policy (E01.2)

  • spouse or domestic partner

  • child, guardian/ward, step-child, foster child

  • mother, father, step-mother, step-father, mother-in-law, father-in-law,

  • brother, sister, step-brother, step-sister, half-brother, half-sister, brother-in-law, sister-in-law,

  • aunt, uncle, first cousin, niece, nephew,

  • grandparent, great-grandparent, grandchild,

  • domestic partner’s mother, domestic partner’s father, domestic partner’s child, or any member of the employee’s household including co-habitation.

 

The offer to teach at the second institute should be disclosed and discussed with your Supervisor prior to accepting any employment or appointments at another institution of higher learning. While there may be situations where you are allowed to teach at a second institution of higher education, your first priority must be RIT, and the second position must not interfere with your role or responsibilities, both in and out of the classroom, at RIT.

Yes. Whenever possible, Employees should not teach their own children or other close relatives in a course for credit. The potential Conflict could have negative effects on both the student/child, as well as on the faculty member’s relation to the other students in the course. In the rare instances in which such enrollment is unavoidable, such as when the parent is teaching a course required for the student’s major, the parent should discuss the situation with the chair of the department in advance of the course. All Employees should disclose to their supervisor the enrollment of his or her immediate family member in a class taught by the Employee or any other circumstance where the employee is in a position to deliver academic services to an immediate family member. Disclosure must occur prior to enrollment in the class or delivery of the other academic services. In no event should the Employee be grading their own child’s work. To avoid an unbiased evaluation, another qualified faculty member should be asked to independently evaluate the work and decide upon the grade.

Yes, because your role of professor at RIT is in conflict with your personal motivation or opportunity to benefit financially from assigning your own book to your students, which calls into question your ability to be fair and unbiased. Indeed, you are not in the best position to judge impartially whether your book is the best book available for the students given the financial benefit you will receive. There is also the appearance of a Conflict. One way to resolve the Conflict may be to have an independent third party such as your dean, administrative chair, or a committee with sufficient expertise to establish a strict and transparent set of criteria for evaluating and reporting on the book to make an independent determination regarding whether the book should be assigned to the students.

Another way may be to forego the royalties from the sale of the books to the students to avoid both the actual and apparent Conflict. This can be achieved by either (i) offering the book at a reduced price based on the percentage of royalties earned from each sale, (ii) having the publisher deduct royalties for that portion of sales at payment time; or, (iii) if self-published as print-on-demand, by offering the book at cost. The ability to collect royalties from sales to all other institutions would not, however, present a Conflict. Additionally, you should review RIT’s Intellectual Property Policy to ensure implementation of proper terms and conditions whereby RIT, Personnel, and Students establish and maintain their interests in Intellectual Property created by or used at RIT.

No, they are aggregated for each single firm or corporation based on the limits. For example, if you and your family received more than $10,000 from Company A in salary, honoraria, etc.; therefore, it must be reported for Company A. However, if you and your family received only $8,000 in salary, honoraria etc. from Company B; then you do not have to report for Company B.