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Note: This policy was updated in February 2024 to accommodate a new electronic process for Conflict of Interest and External Professional Activities for Pay submissions. Please continue to use the paper forms linked at the bottom of this page until further notice.  

Conflicts of Interest, Conflicts of Commitment, and External Professional Activities for Pay

Formerly Executive Memorandum 95-112
Initially Approved: October 19, 1995
Revised: December 12, 2005
Revised: July 10, 2006
Revised: July 16, 2012
Posted: August 17, 2012
Revised: December 19, 2016
Revised: November 23, 2021
Revised: February 27, 2024 

Policy Topic:  Legal & Risk Management, Research and Sponsored Activities, Personnel
Administering Office:  Office of Legal Counsel  

I.  POLICY STATEMENT

Faculty and staff are expected to avoid Conflicts of Interest and Conflicts of Commitment that have the potential to significantly affect the University’s interests or compromise an individual’s objectivity in carrying out their University Employment Responsibilities including the appearance of conflicts, unless such conflicts are disclosed, reviewed, and appropriately managed in accordance with the provisions of this policy and the related procedures. [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.] As outlined herein, all Covered Employees are expected to disclose actual or potential Conflicts of Interest and Conflicts of Commitment.

The purpose of this Policy is to help Covered Employees recognize the types of personal interests, outside activities, and relationships that may create Conflicts of Interest and Conflicts of Commitment in the performance of their University Responsibilities, and to describe the process for disclosure and review of interests, activities, and relationships.

II. SCOPE AND APPLICATION OF POLICY

This Policy applies to Covered Employees as defined by this Policy. 

III. DEFINITIONS 

“Conflict of Commitment” exists when an employee engages in activities external to the University, or assumes commitments external to the University, that may compromise, may appear to compromise, or have the potential to compromise, their ability to fulfill their University Employment Responsibilities. 

“Conflict of Interest” exists when a Covered Employee’s financial or other personal interests or relationships may compromise, may appear to compromise, or have the potential to compromise, a Covered Employee’s objectivity in fulfilling their University Employment Responsibilities.

“Conflict of Interest (COI) Officer” means the person charged with responsibility for: (i) reviewing all Conflict Evaluation Forms; (ii) making the initial determination as to the existence of an actual Conflict of Interest; (iii) working with the relevant supervisor to determine an appropriate management plan for each such a Conflict of Interest; (iv) maintaining records of all such Conflicts of Interest and Management Plans; and (v) responding to requests for information from funding agencies and/or from the public regarding Conflicts of Interest. The COI Officer is WCU’s Chief Compliance Officer or their designee. 

“Conflict of Interest and Commitment Review Panel (COI Panel)” is the panel tasked with reviewing certain disclosures and making a decision in the event of disagreement between the COI Officer and the Covered Employee’s supervisor. The duties and membership of the COI Panel are established in Section VIII of this Policy. 

“Covered Employee” includes the following: 

1. All faculty;
2. All Senior Academic and Administrative Officers (SAAO) and Exempt Professional Staff (EPS), as those terms are defined by UNC Policy Manual 300.2.2;
3. Any University employee or student, regardless of employment type or status, involved in federally funded research including the design, conduct, or reporting of such research; and
4. Any SHRA employee at the request of the applicable Executive Council member for the department or division. 

“Department” means an academic department, a professional school without formally established departments, or any other administrative unit designated by the Chancellor or Provost, or by the UNC System Office, for the purposes of implementing this policy. “Supervisor” refers to the person with supervisory responsibility for the Covered Employee, whether in an academic or non-academic department.

“External Professional Activities” is defined as any activity that (i) is not included within one's University Employment Responsibilities; (ii) is performed for any entity, public or private, other than the University; (iii) is based upon the professional knowledge, experience, and abilities for which the University employer employs the Covered Employee; and (iv) is undertaken for compensation.  

“Financial Interest” is defined as:  

1. Income, such as dividends, royalties, payment for services, consulting fees, honoraria, and paid authorships, received by the Covered Employee or a member of their immediate family, from an entity other than the University employer; 
2. equity or other ownership interest in publicly or non-publicly traded entities (e.g., stock, stock options, warrants, or other ownership interest held by the Covered Employee or a member of their immediate family; or  
3. intellectual property rights and interests upon receipt of income related to such rights and interest, held by the Covered Employee or a member of their immediate family. This includes intellectual property rights assigned to the University and subject to a share in royalties related to such rights.  

Income from investment vehicles, such as mutual funds or retirement accounts, in which the Covered Employee or a member of their immediate family do not directly control or advise the investment decisions are excluded from the definition of Financial Interest. De minimis Financial Interests, defined as Financial Interests valued at $1500 or less, are not considered Financial Interests under this Policy.  

“Immediate Family” includes Covered Employee’s spouse and dependent children.

“Investigator” means the research project director or principal investigator and any other person, collaborator or consultant, regardless of title or position, who is responsible for the design, conduct or reporting of research, or who proposes research funded by the Public Health Service (e.g., National Institutes of Health) or the National Science Foundation.

“SHRA Employee” means an employee who is subject to the State Human Resources Act.

"University Employment Responsibilities” consist of primary duties and secondary duties. Primary duties consist of assigned teaching, scholarship, research, institutional service requirements, administrative duties, and any other assigned employment duties. Secondary duties may include professional affiliations and activities traditionally undertaken by Covered Employees outside of the immediate University employment context. Secondary duties may or may not entail the receipt of honoraria, remuneration (see additional regulations, UNC Policy Manual, 300.2.2.2[R]), or the reimbursement of expenses; include membership in and service to professional associations and learned societies; membership on professional review or advisory panels; presentation of lectures, papers, concerts or exhibits; participation in seminars and conferences; reviewing or editing scholarly publications and books without receipt of compensation; and service to accreditation bodies. These activities, which demonstrate active participation in a profession, are encouraged, provided they do not conflict or interfere with the timely and effective performance of the individual's primary duties or other University policies. All Covered Employees are expected to devote their primary professional loyalty, time, and energy to their University Employment Responsibilities.

“Use of University Resources” means using any University or constituent institution services, facilities, equipment, supplies, or personnel which members of the general public may not freely use.

IV. CONFLICTS OF INTEREST 

1. The University and its Covered Employees shall comply with all applicable state and Federal laws and regulations. A Covered Employee’s professional activities and financial or personal interests shall be arranged to avoid circumstances that do or may prevent or limit objectivity in the performance of University Employment Responsibilities or that otherwise do or may adversely affect any University interests. 
2. The bias that such conflicts can cause may adversely affect many University responsibilities, including, but not limited to, decisions about University personnel, the purchase of equipment and supplies, the selection of contractors and vendors, the selection of instructional material for classroom use, the mentoring of students and assessment of their work, and the design, conduct, or reporting of research.
3. While a Conflict of Interest may result from a relationship, participation in an activity, or other nonfinancial interests, the majority of Conflicts of Interest result from a financial interest of a faculty or staff member who is in a position to make a supervisory, academic, or administrative decision which may be compromised because of the potential for personal financial gain.
4. Covered Employees with administrative responsibilities must take particular care to avoid other relationships that have the potential to advantage the individual but affect adversely the University's interests. Among the relationships that may adversely affect the University's interests are those that might adversely affect the professional academic advancement of colleagues, or those that might otherwise inject inappropriate considerations into administrative decisions.

V. CONFLICTS OF COMMITMENT 

1. Conflict of Commitment relates to an individual’s distribution of time and effort between obligations to University employment and participation in external professional activities. which may include professional affiliations and activities traditionally undertaken by Covered Employees outside of the immediate University employment context. These duties may include but are not limited to:
   1. membership in and service to professional associations and learned societies;
   2. membership on professional review or advisory panels;
   3. presentation of lectures, papers, concerts or exhibits;
   4. participation in seminars and conferences;
   5. reviewing or editing scholarly publications and books without receipt of compensation; and
   6. service to accreditation bodies.
      
      Such activities often promote professional development and enrich one’s contributions to the institution, their profession or discipline, and to the community, and are generally encouraged. However, a Conflict of Commitment occurs when the pursuit of outside activities involves an excessive investment of time or is conducted at a time that interferes with the Covered Employee’s fulfillment of University Employment Responsibilities.
      
      
2. Although faculty and certain non-faculty employment is not amenable to precise, time-clock analysis and monitoring, administrators at the department and school levels regularly evaluate the work of Covered Employees within their units. The formal occasions for determining whether an individual is devoting sufficient time and energy to University Employment Responsibilities include annual performance reviews and scheduled reviews incident to promotion, reappointment, or tenure decisions. In addition, complaints from students, colleagues, or administrators about possible failures to meet assigned responsibilities may arise and require investigation. The issue, in each case, is whether the Covered Employee is satisfying their University Employment Responsibilities. If presented with evidence that he or she is not, the Covered Employee may be subject to disciplinary action, including the possibility of discharge, for neglect of duty or unsatisfactory performance, as applicable.

VI. DISCLOSURE OF POTENTIAL CONFLICTS OF INTEREST AND CONFLICTS OF COMMITMENT

1. Disclosures Required 
   
   
   1. Annual Conflict of Interest Disclosure 
      
      All Covered Employees are required to complete and submit the Annual Evaluation of Potential Conflict of Interest or Commitment form in accordance with the procedures supplemental to this Policy. [Note: Please continue to use the paper form linked at the bottom of this page until further notice.] In addition to the annual disclosure requirement, faculty and staff must disclose new financial interests, relationships, or activities as they arise throughout the year. The disclosure requirements also apply to all individuals on leave from the University if that leave is funded at least partially from University sources. Additional details on the completion and submission of annual disclosures are found in the procedures supplemental to this Policy. [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.]
      
      
   2. Project-Specific Conflict of Interest Disclosure for Externally Funded Projects 
      
      All Covered Employees are required to complete a project-specific Conflict of Interest form with each grant proposal submitted through InfoEd. [Note: Please continue to use the paper form linked at the bottom of this page until further notice.] This requirement is in addition to the annual disclosure requirement described in Section A.1. Additional details on the completion and submission of project-specific disclosures are found in the procedures supplemental to this Policy. [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.]
      
      
2. Annual Disclosure Review, Management, and Monitoring 
   
   
   1. The COI Officer shall review all annual forms and determine whether or not the information disclosed in each represents a potential Conflict of Interest or Conflict of Commitment. 
   2. Upon making the determination that there is a potential Conflict of Interest, the COI Officer will forward the disclosure form with a preliminary analysis and recommendation for resolving or managing the potential conflict to the Covered Employee’s first-level supervisor ("Reviewing Officer"). 
   3. The Reviewing Officer shall issue a decision regarding the disclosure within fourteen (14) calendar days of receipt of the annual disclosure, provided that the deadline may be extended by the COI Officer for good cause. 
   4. Where the Reviewing Officer agrees with the COI Officer’s analysis and recommendation, the Reviewing Officer shall approve the analysis and recommended action, and the Covered Employee shall receive a notification of the form’s approval and any recommended action. 
   5. Where the Reviewing Officer disagrees with the COI Officer’s analysis and recommendation, the Reviewing Officer shall explain the basis for that decision and the annual disclosure is referred to the COI Panel for review. The COI Panel may accept or reject the Reviewing Officer’s decision and order further measures to resolve or manage the COI. 
   6. Conflict Management 
      If necessary to avoid or manage a potential or existing Conflict of Interest or Commitment, the COI Manager shall facilitate development of a Conflict of Interest or Commitment Management Plan with the Covered Employee, the Covered Employee’s supervisor, and others as appropriate. The COI Panel shall review and approve all Conflict Management Plans, and the Covered Employee’s second-level supervisor shall receive notice of the approved Conflict Management Plan. Once finalized, the employee must comply with the Conflict Management Plan for the duration of the subject activity.
   7. Monitoring 
      Monitoring of activities related to Conflicts of Interest and Conflicts of Commitment is the responsibility of the Covered Employee’s supervisor, in consultation with the COI Officer. Changes in circumstances must be disclosed in an update to the Annual Disclosure form within thirty (30) calendar days of the acquisition a new financial or personal interest. The COI Manager and Covered Employee’s first-level supervisor are responsible for reviewing, issuing a decision on, and making any necessary adjustments to the Management Plan in accordance with this Section.
   8. Appeals
      If disagreement exists between the Covered Employee and administration regarding the permissibility of identified activities or management mechanisms required in the Conflict of Interest Management Plan, the Covered Employee may appeal the decision to the responsible Executive Council member as described in the procedures supplemental to this Policy. [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.]
      
      
3. Categories of Potential Conflicts of Interest and Commitment 
   
   The following categories may pose a Conflict of Interest or Conflict of Commitment and must be avoided or disclosed and managed.
   
   
   1. Activities That Are Generally Allowable but Must Be Disclosed
      
      The following activities are generally allowed because they do not compromise the objectivity of research results, the integrity of faculty-student interaction, decision-making, or other interests of the University, a sponsor, or the public. These relationships are generally minimal in their personal financial impact, and otherwise do not represent a potential source of unreasonable bias. If these relationships involve the receipt of compensation or reimbursement, they must be reported at least annually so long as they continue to exist, and may be subject to investigation and further oversight by appropriate University personnel. These activities may include but are not limited to:
      1. Receipt of royalties or other payments for scholarly works, other writings, or for inventions, pursuant to Policy 130 or Policy 84, that result in more than a de minimis Financial Interest. 
      2. Receipt of compensation in the form of honoraria or reimbursement in connection with service to professional associations, service on review panels, presentation of scholarly works, and/or participation in accreditation reviews, and which result in more than a de minimis Financial Interest.
         
         
   2. Activities Requiring Disclosure for Further Administrative Review and Analysis 
      
      The following activities may be allowed following administrative review and analysis. Such activities may necessitate supervisory procedures, including a Conflict of Interest Management Plan, be put in place to prevent bias or inappropriate activities and to ensure academic standards and institutional integrity. Examples may include but are not limited to: 
      1. Requirements that students purchase a textbook or related instructional materials written or copyrighted by faculty or staff, or members of their immediate family, which produces compensation for the faculty, staff or family member.
      2. Receipt of compensation, gifts, or gratuities from any individual or entity doing business with the University. Note that no University employee may seek or receive any gift, reward, or promise of reward for recommending, influencing, or attempting to influence the award of a contract by their employer. (See N.C.G.S. 14-234 and N.C.G.S 138A).
      3. Service on the board of directors or scientific advisory board of an enterprise that provides financial support for University research when the Covered Employee, or a member of their immediate family, may benefit from such financial support.
      4. An equity or ownership interest in a publicly or non-publicly traded entity or enterprise held by a Covered Employee, or a member of their immediate family, that does business with the University or is related to their university employment responsibilities.
      5. Receipt of financial support for University research under conditions that require research results to be held confidential, withheld from publication, or inordinately delayed in publication. Research conducted by faculty or students under any form of sponsorship must maintain the University’s open teaching and research philosophy and must adhere to a policy that prohibits secrecy in research. Such conditions on publication must be in compliance with UNC Policy Manual, 500.1 and 500.2, and with Policy 84, Copyright Policy, and Policy 130, Patent Policy. 
         
         
   3. Activities That Are Generally Not Allowable or Permitted Unless an Approved Conflict of Interest Management Plan is in Place
      
      The following activities present such serious problems that they are generally presumed to be inappropriate. In such cases, a heavy burden will rest with the Covered Employee to demonstrate to the University’s satisfaction the compatibility of such practices with University policy prior to going forward with the proposed activity and the implementation of an approved Conflict of Interest Management Plan. Such activities may include but are not limited to: 
      
      
      1. University research that involves the use of a technology owned by, or contractually obligated to (by license or an option to license, or otherwise) the Covered Employee, or to an enterprise or entity in which the Covered Employee or a member of their immediate family has a consulting relationship, holds an equity or ownership interest, or holds an executive position.
      2. Receipt of grant or contract funding for University research from an enterprise or entity in which the Covered Employee or a member of their immediate family has an equity or ownership interest.
      3. Assignments of students or other trainees to University research projects sponsored by an enterprise or entity in which the Covered Employee or a member of their immediate family has an equity or ownership interest.
         
         
   4. Activities that are Not Allowable under Any Circumstances
      
      
      1. Referring University business to an external enterprise in which a Covered Employee or a member of their immediate family has a financial interest.
      2. Any activity that is against State or federal law, or University Policy, including but not limited to: 
         1. Negotiating or administering a contract on behalf of the University from which a Covered Employee derives a direct benefit from the contract. (N.C.G.S. 14-234) 
         2. Attempting to influence any other person who is involved in making or administering a contract with the University in which the Covered Employee will benefit. (N.C.G.S. 14-234)
         3. Soliciting or receiving any gift, favor, reward, service, or promise of reward, including a promise of future employment, in exchange for recommending, influencing, or attempting to influence the award of a contract by the University. (N.C.G.S. 14-234)
      3. Associating their name with the University in such a way as to profit financially by trading on the reputation or goodwill of the University.
      4. Making unauthorized use of privileged information acquired in connection with one’s University responsibilities.
      5. Signing agreements that assign University patent and other intellectual property rights to third parties without prior University approval.
      6. Receiving remuneration from both the University (including State-reimbursed travel, work time, or resources) and an external entity for the same activity. 

VII. EXTERNAL PROFESSIONAL ACTIVITIES FOR PAY (EPAP) 

1. Applicability
   
   This Section applies to Covered Employees: 
   
   
   1. Who are classified as 0.75 FTE or greater, unless otherwise specified by the Covered Employee’s Dean;
   2. Who work in a permanent position; and 
   3. Whose external activity for pay is conducted concurrently with a contract service period, including during the summer when teaching or conducting grant- or contract-funded activities. 
      
      
2. EPAP Requirements
   
   EPAPs should generally be limited to no more than the equivalent of twenty percent (20%) of the Covered Employee’s contracted time. Such activities may be undertaken only if they do not: 
   1. 1. Create a Conflict of Commitment with the individual's ability to carry out all Primary Duties in a timely and effective manner; 
      2. Create a Conflict of Interest; 
      3. Involve any inappropriate use or exploitation of University resources, i.e., using any services, facilities, equipment, supplies, or personnel which members of the general public may not freely use for other than the conduct of University Employment Responsibilities; 
      4. Make any use of the name of the University of North Carolina or Ģ������Ƶ for any purpose other than professional identification; or 
      5. Claim, explicitly or implicitly, any University or institutional responsibility for the conduct or outcome of the EPAP. 
         
         
3. Required Disclosure
   
   Any Covered Employee defined in Paragraph A who plans to engage in EPAPs must complete the "Notice of Intent to Engage in External Professional Activity for Pay" ("Notice of Intent"). A Notice of Intent must be completed online for each proposed activity at least ten (10) calendar days before beginning the activity. [Note: Please continue to use the paper form linked at the bottom of this page until further notice.]
   
   All employees who engage in external professional activities for pay, regardless of whether performed during or outside of the academic year, must also annually disclose financial interests in accordance with UNC Board of Governors’ Policy 300.2.2 and Section V. of this Policy.
   
   
4. Exemptions 
   
   Faculty serving on academic-year contracts (i.e., traditional nine-month faculty without a summer session contract) are exempt from this Section if: 
   
   
   1. The External Professional Activity for Pay is wholly performed and completed outside the academic year; and
   2. The activity does not otherwise conflict with University policies.
      
      Part-time Covered Employees (i.e., less than .75 FTE) are exempt from this Section but are subject to the annual disclosure requirements in Section V.A.
      
      SHRA employees are not covered by this Section. SHRA employees who wish to engage in secondary employment are covered by Policy 87, Secondary Employment Policy. 
      
      
5. Special Circumstances
   
   
   1. EPAPs performed at other UNC institutions or State agencies
      
      EPAPs performed for another UNC institution or agency of the State of North Carolina must also comply with the applicable State and Ģ������Ƶpolicies governing dual employment and compensation, unless an exception to those policies is expressly authorized by the Chancellor or the President. 
      
      
   2. Honoraria 
      
      In those instances when State-reimbursed travel, work time, or resources are used or when the activity can be construed as related to the Covered Employee’s University Employment Responsibilities on behalf of the State, the Covered Employee shall not receive any financial consideration, including an honorarium. In these instances, the employee may request that the honorarium be paid to the University. The honorarium may be retained by the employee only for activities performed outside of normal working hours, as defined by WCU, or while the employee is on approved leave, and all expenses are the responsibility of the employee or a third party that is not a State entity. Third party support may need to be disclosed by the Covered Employee. 
      
      
   3. Political Candidacy
      
      The Board of Governors has established rules for monitoring and regulating the involvement of University employees in political candidacy and office-holding that could interfere with full-time commitment to University Employment Responsibilities, contained in the UNC Policy Manual, 300.5.1 and 300.5.2. 
      
      
6. EPAP Review, Monitoring, and Appeals 
   
   
   1. The Notice of Intent shall initially be reviewed by the employee's first-level supervisor Department (“Reviewing Officer”). If the reviewing officer determines that the proposed activity is not consistent with this Policy, the employee shall be notified of such determination within ten (10) days of the date the Notice of Intent was filed. If a Notice of Intent is disapproved, the Covered Employee shall not proceed with the activity but may appeal the determination in writing to the administrative officer to whom the Reviewing Officer reports (i.e., the Covered Employee’s second-level supervisor), and then to the COI Panel. The decision of the COI Panel shall be final.
   2. If the Reviewing Officer approves the form and the Notice of Intent discloses either: (i) a proposed activity for an entity that provides funding that directly supports the Covered Employee’s University Employment Responsibilities or activities, or (ii) a proposed activity for a private entity in which the Covered Employee or member of the Covered Employee’s Immediate Family holds an equity or ownership interest or holds an office, the Reviewing Officer’s supervisor shall also review and approve or disapprove the Notice of Intent within ten (10) days of receipt. An appeal of a disapproval by that officer shall be to the COI Panel. The decision of the COI Panel shall be final.
   3. After approval by the relevant supervisor(s), the COI Officer shall review the form to ensure compliance with this Policy. 
   4. Approval of EPAPs may be granted for a period not to exceed the balance of either:
      1. The fiscal year in the case of 12-month employees and employees with contracts that include summer session; or 
      2. The academic year for nine-month employees with no summer session contract. 
   5. If the approved activity will continue beyond the end of the relevant fiscal or academic year in which it began, the Covered Employee must file an additional disclosure before engaging in the activity in the succeeding year.
   6. Monitoring of activities related to External Professional Activities for Pay is the responsibility of the Covered Employee’s supervisor. Changes in circumstances must be disclosed by the Covered Employee.
      
      
7. Additional Requirements for SAAO and EPS Employees
   
   In accordance with the UNC Policy Manual, 300.2.2.2[R], the following requirements apply to the external professional activities of specific categories of employees:
   
   
   1. SAAOs must use annual leave if they wish to engage during the conventional University workweek in external activities that produce income for them.
   2. SAAOs and EPS employees are prohibited from receiving honoraria unless:
      1. the activity is performed during non-working hours or while the employee is on annual leave,
      2. the State has no responsibility for paying expenses associated with the activity, and
      3. the activity is not part of the employee's State duties.

VIII. CONFLICT OF INTEREST AND COMMITMENT REVIEW PANEL

The Conflict of Interest and Commitment Review Panel (“COI Panel”) is comprised of the following individuals, who shall serve by virtue of their office: (1) the General Counsel or their designee; (2) Chief Compliance Officer, who shall serve as chair of the panel; (3) the Associate Provost; or their designee; (4) the Director of Research Compliance and Integrity;  and (5) the Associate Vice Chancellor for Human Resources or their designee.

The COI Panel shall be responsible for (i) providing counsel and assistance to Covered Employees in disclosing potential Conflicts of Interest and Commitment and to supervisors in making Conflict of Interest determinations; and (ii) reviewing and approving proposed Management Plans regarding Conflict of Interest management, mitigation or elimination. 

IX. FEDERAL RESEARCH STANDARDS

Although this Policy applies to conflicts which may arise with respect to any research or non-research activity conducted under University auspices, regulations issued by the National Science Foundation (“NSF”), Public Health Service (“PHS”), and the National Aeronautics and Space Administration (NASA) establish specific requirements for University research funded by those agencies. Covered Employees are required to comply with the standards set forth by the relevant funding agency and may be required to disclose additional information. In the event federal agencies or other external sponsors impose additional disclosure requirements, disclosure to the sponsor must also include disclosure to the University. Research-specific Conflict of Interest procedures are supplemental to this Policy.  [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.]

Consistent with Federal Acquisition Regulation (FAR) Subpart 9.5, the University is committed to identifying, avoiding, and/or managing actual or perceived Organizational Conflicts of Interest (OCIs) in research activities in its capacity as a federal awardee or contractor. An OCI may arise when members of the University assist in the development of new federal programs or federal contract specifications, and the University subsequently competes for federal support through the new programs or contracts.

This Policy is designed to comply with the National Science Foundation's Recipient Standards (PAPPG)(NSF 23-1) dated January 30, 2023, the U.S. Department of Health and Human Services Promoting Objectivity in Research Rules, 42 CFR Chapter I, Subchapter D, Part 50, Subpart F as amended January 2, 2016 and the General Services Administration Federal Acquisition Regulations Subpart 9.5 effective June 2, 2023.

Please see the Supplemental Procedures for Project-Specific Conflicts of Interest for more information. [Note: Supplemental procedures will be posted when implementation of the electronic process is complete.]

X. TRAINING

The University shall provide training on the substantive requirements of this Policy to Covered Employees. The University provides this training through the Conflict of Interest Training website, located here. [Note: The website link will be posted when implementation of the electronic process is complete.] 

Investigators who participate in research funded by the PHS must complete required training prior to engaging in agency supported research and at least every four (4) years thereafter, and immediately when the Investigator is found to be in violation of this Policy or an applicable Management Plan.

XI. CONFIDENTIAL RECORDS; REQUIRED REPORTING

Completed disclosure forms, including attachments and supplemental documentation, are confidential personnel records as defined by the North Carolina Human Resources Act (). The provisions of that Act governing access to and confidentiality of personnel records shall be strictly observed; provided, however, that the University may be obligated to report disclosed or undisclosed Conflicts of Interest and make certain information publicly available under federal regulations.

XII. ENFORCEMENT AND REPORTING VIOLATIONS OF THIS POLICY

Covered Individuals who do not comply with the provisions of this policy will be subject to disciplinary action.

A member of the University community who has reason to believe that another individual has an undisclosed Conflict of Interest or is otherwise violating University policy or federal law and regulations must report the concern to his or her immediate supervisor. Should the allegation(s) be considered by the supervisor to constitute a possible undisclosed conflict or other serious violation of this Policy or federal law and regulations, the supervisor shall report the matter to the Office of Research Administration for investigations related to sponsored research, and to the COI Officer for investigations related to all other matters.  

XIII. POLICY REVIEW

This Policy shall be reviewed and revised as necessary every four (4) years.

XIV. RELATED POLICIES AND RESOURCES

University Policy #87, SHRA Employee Secondary Employment Policy
UNC Policy 300.2.2
UNC Policy 300.2.2 [G]
UNC Policy 300.2.2.1 [R]
UNC Policy 300.2.2.2 [R]
Ģ������ƵOffice of Research Administration Conflicts of Interest

Agencies and Organizations Following PHS COI Regulations

Supplemental Procedures (to be added) 
Supplemental Procedures – Project-Specific Conflicts of Interest