Conflict of Interest & Commitment

Employees need to disclose any outside activities, financial interests, relationships, or other factors that create an actual, perceived, or potential conflict of interest or commitment. The disclosure is required, at a minimum, annually or right away, if a change in circumstances 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.

When a conflict is disclosed, supervisors need to decide if it can be managed. If it can, supervisors must create a written Management Plan to address the conflict. Management Plan templates, the ICIC Guidance document, and the Guidance for Management Plans (see below), can assist in developing effective 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 Records Management Policy.

Supervisors must oversee compliance of their employees' Management Plans.

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 that you want RIT students to buy for your course.
• Participating in employment decisions that involve or directly affect your Immediate Family or Relative.
• Buying office supplies for your department from a company owned by you or an Immediate Family or Relative, or from which the sale would benefit you or your Immediate Family or Relative.
• Selecting or collaborating with your spouse's technology company on 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 related to your work at RIT.
• Using your name in a way that suggests that your views represent the university's views.
• Accepting personal gifts from companies competing for RIT business.

Additionally, you are responsible for making sure any agreements you sign as part of outside activities do not prohibit RIT's competitive involvement or claim ownership of resulting work related to your central role or responsibilities at RIT. If you have questions, talk to your immediate supervisor, who can seek clarification from the university if needed.

Examples of situations that generally do not require disclosure include:

• Serving as an officer, board member, or volunteer in a professional, community-based, or charitable organization.
• Receiving an honorarium as a one-time payment for a speaking engagement (unless it's part of a consulting arrangement, which should be disclosed).
• Serving on a government panel or commission where 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 with questions about disclosing situations should talk with their immediate supervisor.

When there is an outside activity, financial interest, business or personal relationship, or other factor otherwise prohibited by policy, it is essential to disclose it immediately. After disclosure, the situation can proceed if an appropriate Management Plan is in place to eliminate the conflict, prevent bias from interfering with university-related decision-making, and provide mechanisms for ongoing oversight.

Red Designation Scenario Example:

• An employee has a financial interest in an outside company that does business with RIT.
• This employee might refer students or staff to that company, leading to personal gain.
• The employee's financial interest in the outside company could potentially compromise their professional judgment in their university duties.

An employee's outside activity, financial interest, business or personal relationship, or other factor can also result in a potential or perceived conflict. In these situations, activities are likely permissible, but having a detailed Management Plan reduces the risk of an actual conflict arising now or in the future.

Yellow Designation Scenario Example:

• The employee cannot influence business decisions related to their external outside activity, financial interest, business or personal relationship, or other factor.
• The appearance (perception) of influence exists, due to employee's association, interest, or relationship.
• A Management Plan is recommended.

In this case, no actual conflict exists yet, but it is reasonably possible that the scenario will change in the future and require a Management Plan. For example, an faculty member's immediate family member is enrolled at RIT but not currently in the faculty member's department or class; however, there is the potential for the family member to change majors to the faculty member's department and/or be assigned a course with the faculty member in the future.

While a Management Plan is not required for the above scenario, it is recommended and caution should be exercised.

Not all outside activities, financial interests, relationships, or other factors present an actual, potential, or perceived conflict. In such cases, the disclosed situations can proceed without a Management Plan.

Green Designation Scenario Example:

• The outside activity is part of the employee's regular employment responsibilities (like "academic activities" for faculty).
• The outside activity, financial interest, relationship, or other factor does not and cannot compromise or appear to compromise the employee's professional judgment (for example, in teaching, research, or business decisions).