The policy, approved by the Corporation of Brown University, requires annual and ongoing disclosure of potential or actual conflicts. This process helps ensure that all decisions and actions are made in the best interests of the University and in alignment with ethical standards.

Determining whether a conflict exists is the University’s responsibility. The process asks you to disclose relevant financial and outside interests so they can be reviewed objectively, including consideration of how situations may be perceived by others.

All staff must submit a disclosure annually. Seasonal or intermittent employees are not required to complete the annual process but are still subject to the policy and must disclose conflicts if they arise.

The annual disclosure process takes place each year between February and March and is completed in Workday. You will receive instructions when the process opens. Disclosures cover the previous calendar year.

Yes. If a new situation arises, such as outside employment, starting a business, board service, public office or a family member enrolling or working at Brown, you must submit an updated disclosure.

• Spouse or domestic partner
• Parent, stepparent or parent-in-law
• Child, stepchild or child-in-law
• Sibling, step-sibling or sibling-in-law
• Grandparent or step-grandparent
• Grandchild or step-grandchild
• Guardian, ward or other member of one’s household

Yes. You are required to disclose your child’s enrollment at Brown. Because some staff roles may influence a student’s experience, disclosure helps ensure appropriate steps are taken to prevent actual or perceived preferential treatment.

You must disclose outside work if it results in earnings of $5,000 or more, or if it relates to your University responsibilities. Disclosure helps ensure there is no conflict with your duties at Brown.

Yes. Any ownership or equity interest in a privately held company must be disclosed, even if the company has no income or employees.

• Not reportable: Mutual funds or investments where you do not control individual stock selection
• Reportable: Stocks you directly control that meet the $5,000 threshold and relate to your role

• Gifts over $100 (or of unclear value) from donors, students, parents or business contacts must be declined or returned
• Gifts of $100 or less may be accepted but must be reported to your supervisor and disclosed annually

Individual departments may have stricter gift restrictions. This does not apply to personal gifts received outside of your relationship with Brown, such as birthday gifts between relatives. 

University resources, including your Brown email, may not be used for political activities. See the Political Activities Policy, Brown's Acceptable Use of Information Technology Resources Policy and Email Policy.

Managers review disclosures for their direct reports and determine whether a management plan is needed. Some cases are escalated to a Conflict of Interest and Commitment Review Committee, with input from relevant University offices and, if necessary, the Office of General Counsel.

You can access your past Conflict of Interest and Commitment Disclosure forms by running the “My Conflict of Interest and Commitment Forms” report in Workday. This report includes your submitted disclosures, management plans, and any supporting attachments.