Resources for Non-Research Conflicts of Interest & Commitment and Avoiding Nepotism
The university is committed to upholding ethical standards in the workplace. All members of the Cornell University community are expected to carry out their workplace responsibilities in a manner consistent with their primary ethical, employment, and contractual commitments to the university.
This obligation includes avoiding or minimizing actual or perceived conflicts of interest and conflicts of commitment and preventing the occurrence of or potential for favoritism or nepotism in the workplace.
All employees must comply with university policies related to conflicts of interest and commitment and avoiding nepotism that affect their professional responsibilities and obligations to the university.
Covered Here:
- University Policy 4.14, Non-Research Conflicts of Interest and Commitment
- University Policy 6.14, Avoiding Nepotism
For guidance on research-related conflicts requirements, please see University Policy 1.7, Research Related Conflicts of Interest and Commitment and the Office of Research Integrity and Assurance (ORIA) website: https://researchservices.cornell.edu/compliance/conflict-of-interest.
Weill Cornell Medicine (WCM) employees should refer to WCM’s Conflict of Interest Office website: https://research.weill.cornell.edu/compliance/conflicts-interest-office for further guidance.
Non-Research Conflicts of Interest and Commitment
University Policy 4.14, Non-Research Conflicts of Interest and Commitment requires all employees to disclose any potential, actual, or perceived conflicts to supervisors or their unit head.
What is a Conflict of Interest (COI)?
Under Policy 4.14, a conflict of interest exists whenever an employee’s external interests, activities, or relationships compete with or are perceived to compete with the interests, activities, or concerns of the university such that the employee’s actions or decisions on behalf of the university or related to that employee’s employment responsibilities, are compromised, or appear to be compromised.
What is a Conflict of Commitment (COC)?
Under Policy 4.14, a conflict of commitment exists when an employee’s external relationships, activities, or commitments may burden, compete, or interfere with that employee’s primary obligations and commitments to the university.
Avoiding Nepotism
University Policy 6.14, Avoiding Nepotism requires disclosure of any family ties or personal relationships to prevent the occurrence of or potential for favoritism or nepotism in employment decisions involving an employee’s family member or an individual with whom an employee has a personal relationship.
What is Nepotism?
Under Policy 6.14, nepotism means favoritism, bias, or the appearance of or potential for bias shown on the basis of a familial or personal relationship, including with those with whom one is having a consensual relationship (defined in University Policy 6.3, Consensual Relationships).
Managing Conflicts is a Shared Responsibility
In addition to reviewing and understanding your responsibilities under policies 4.14 and 61.4, employees should always consider these shared responsibilities:
- For all employees: Conflicts should be avoided or resolved through the exercise of individual judgment or discretion. In other words, employees should arrange their affairs so that there is no conflict of interest or commitment.
- For all employees: Relationships that may provide opportunity for bias or have the appearance of bias, including nepotism, must be disclosed to supervisors or their unit head and appropriately managed.
- For all employees: Full disclosure of the circumstances surrounding a real or potential conflict or potential for nepotism should be made prior to making the commitment or initiating the activity that poses the possible conflict.
- For supervisors: the university may approve a transaction or affiliation, provided that the conflict can be managed. In many cases, the conflict can be managed through disclosure. In some cases, the employee may be required to report on the conflict annually. The university will disapprove the transaction or affiliation if the conflict involved cannot be managed.
Annual Attestation:
Conflicts of Interest and Commitment (Non-Research) and Avoiding Nepotism
On an annual basis, all employees will be assigned a course/attestation via Workday Learning to acknowledge their understanding of policies 4.14 and 6.14. Employees are expected to complete the course/attestation in a timely manner.
The content of the attestation is below:
I acknowledge that I have read and understand University Policy 4.14, Non-Research Conflicts of Interest and Commitment and University Policy 6.14, Avoiding Nepotism, and agree to abide by these university policies. I understand my obligation to avoid actual, potential, or apparent conflicts of interest or commitment, including any potential for nepotism, and to communicate any potential conflicts to my supervisor. I also understand that if I am unsure whether I should disclose a matter, I can discuss my question with my local HR representative.