Conflict of Interest Disclosure Form
UConn employees are state employees, and therefore must follow The State Code of Ethics. The State Code of Ethics maintains that a conflict of interest exists when a state employee is required to take an action in which they, their family member, or a business with which they are associated would financially benefit. According to The Code, the term "family member" includes the employee's spouse, parent, sibling, child, spouse of the employee's child, and/or dependent relative who resides in the employee's household.
Employees are required to disclose any potential or actual conflicts of interest prior to taking any action that may present the conflict. The Conflict of Interest (COI) Disclosure Form is designed for employees to disclose these conflicts and document mitigation plans.
Conflicts of Interest in Research
A Financial Conflict of Interest (FCOI) in Research exists when an Investigator’s Significant Financial Interest (SFI) is related to a research project and could directly and significantly affect the design, conduct or reporting of the research. Investigators are required to disclose all SFIs (including those of a spouse or dependent child) that meet thresholds as defined by policy. Research Integrity & Compliance can guide you through applicable policies and procedures.
Managing Conflicts of Interest
Examples of Mitigation Plans
A conflict of interest occurs when a personal benefit could influence—or appear to influence—your professional judgment. These conflicts can arise in various ways. Below are some examples of conflicts of interest and the plans that could be put in place to mitigate them. Remember every situation is unique. These examples are intended to be helpful, but please seek guidance on your specific circumstances.
Please note that it is required to provide written disclosure of a conflict of interest, and have it reviewed by the supervisor. Disclose conflicts of interest through the online form available here.
Research
Tricia is a research professor in Biomedical Engineering and is applying for a research grant as the Primary Investigator (PI). If awarded the grant, she intends to hire her spouse, Cameron, to work in her lab as a Research Associate since Cameron has specialized expertise that would be valuable to the research. According to The State Code of Ethics, Tricia would have a conflict of interest if she hires her spouse because - as the PI on the grant - she would be determining the allocation of the grant money to fund Cameron's salary. In addition, as the PI, she would be directly supervising Cameron.
Solution: Someone more senior to Tricia, such as the Department Head or Dean, would need to evaluate Cameron’s qualifications for the Research Associate Position and independently determine whether or not to hire Cameron to work on the grant. If awarded the grant, Cameron would need to report to someone other than Tricia. Cameron could report to the Department Head or to another faculty member who has the appropriate expertise, who is not subordinate to Tricia. That person would also need to be responsible for the review and allocation of research funds, including any decisions related to funding Cameron’s position.
Search Committees
Carlos is the chair of a search committee. His role involves deciding who is going to get interviewed and making the ultimate recommendation on who will be hired for the role. While reviewing applications, Carlos realizes his sister-in-law applied for the position.
Solution: While Carlos might think he can mitigate the conflict of interest by only recusing himself from evaluating his sister-in-law's application and participating in his sister-in-law's interview, our recommendation would be that Carlos recuse himself from the search committee entirely. Doing so would best avoid the perception of a conflict of interest by others, especially to those applying to the position.
Student Employment
Dom is a staff member within the Student Employment division of the Office of Student Financial Aid Services. Dom's role involves processing student employment hires for units across the University. Dom realizes that their child, who is a UConn student, was recently hired for a student employment position.
Solution: A different staff member who is not subordinate to Dom will need to process the student's employment.
Vendors
Carla is an Administrative Coordinator and one of her responsibilities is to order restaurant catering for departmental meetings. She has always ordered catering from the same restaurant throughout the years. Recently, she and the owner of this restaurant were married. According to the State Code of Ethics, Carla now has a conflict of interest. If she authorizes payment to her spouse's restaurant, she would be using her state position to financially benefit her family member and their associated business.
Solution: The department could seek a different vendor for catering. Should the department want to continue to order from the same restaurant, Carla cannot authorize payment to her spouse's restaurant. A different employee who is not subordinate to Carla must authorize the payment instead.