All such updated disclosures shall be forwarded to the designated official. In those instances where there may be a newly arisen conflict, the designated official will refer the matter to the appropriate COI committee. Such statements will be maintained for one year, except that in those cases where there is a sponsored research agreement, the period will be three years from the award completion date of the agreement or until resolution of any action regarding the records has been reached, whichever is longer. Disclosures are to be used to determine whether a faculty or staff member has a conflict of interest . A faculty or staff member who refuses to comply with policies and procedures in relation to disclosure will be subject to penalties, as described below.
Disclosures are to be made in writing.
Members of the Executive Working Group submit their disclosures to the President. When the appropriate COI committee determines that a possible conflict of interest exists, the committee will work with the faculty or staff member informally to resolve the issue. The designated official, as appropriate, will initiate informal conflict resolution procedures to resolve the supposed conflict of interest . If an agreement on resolving the supposed conflict of interest cannot be reached, the designated official, with the assistance of University Counsel, will prepare a written opinion as to whether reported activities or commitments constitute a conflict of interest , or whether a potential conflict of interest exists and, if a conflict of interest or potential conflict of interest exists, what actions must be taken to eliminate or manage the conflict, or reduce the possibility that a conflict might arise in the future. The University expects the faculty or staff member involved in a relationship in which there is potential or actual member involved in a relationship in which there is potential or actual conflict of interest to disclose the relationship, and to work with the appropriate University officer to implement plans for resolving the situation promptly.