Managing a Potential Conflict of Interest or Conflict of Commitment
What are some of the ways in which COI/COC managers could address potential COI/COCs?
A COI/COC manager may select one or more of a range of actions, some of which are described below.
- Document that the staff member has disclosed the potential COI/COC, with no further action required.
- Adjust the work schedule for staff member so that the outside activity/employment does not cause a time conflict with the U-M activities.
- Disclose the situation to appropriate personnel within the U-M or to appropriate persons or organizations outside the U-M.
- Modify the staff member’s duties with regard to managing, supervising, evaluating, or mentoring other persons where those activities contribute to the potential COI/COC.
- Request competitive bids for a service/product provided by an entity where the staff member has a financial interest.
- Obtain Regents’ approval to proceed with a contract where the staff member has a special interest (including financial) in the outside supplier/vendor/consultant.
- Prohibit the staff member from being involved in decision-making related to the outside activity/employment. Examples: no involvement in drafting a Request for Qualifications (RFQ), no involvement in selecting consultants, no oversight of outside entity when that entity is doing work for U-M, etc.
- Prohibit the staff member from participating in the outside activity/employment.
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