University Human Resources

Conflict of Interest and Commitment Management Plans

When a conflict of interest or commitment is identified, staff must work with their manager to develop a management plan that appropriately addresses the situation. Management plans are submitted in Workday as part of the Conflict of Interest and Commitment Disclosure form, either during the annual disclosure process or when a new conflict arises during the year.

When a Management Plan Is Required

A management plan is required in the following situations, and submission of the form in Workday serves as the staff member’s electronic signature.:

  • Familial relationships: When a family relationship creates a conflict, the plan must clearly outline how the individual with greater authority or seniority will avoid participating in, influencing or making decisions about the employment or engagement of the other individual.
  • Outside employment, financial interests or public service: The plan must ensure that:
    • The staff member’s role at Brown is not used to support outside interests
    • University responsibilities remain the staff member’s primary obligation
    • Brown resources (including systems, equipment and supplies) are not used for outside activities
  • Service in elected political office: Political Activities Management Plan must be completed to address any related conflicts.

What to Include in a Management Plan

The length and level of detail will vary depending on the nature of the conflict. At a minimum, each plan should describe the measures in place to mitigate risk and protect the University’s interests.

Management plans should include:

  1. Staff member’s name, title and department
  2. Supervisor’s name and title
  3. A summary of the staff member’s primary duties at Brown
  4. Details of the external relationship or interest, including:
    • Name of the individual, business or organization
    • Nature of the relationship
    • Relevant dates, hours or level of involvement
    • Relationship to Brown (e.g., vendor, consultant, donor, student, parent, employee, business partner or investment interest)
  5. Description of the conflict, including:
    • Whether it is actual, potential or perceived
    • How the situation could create risk for the University
    • Examples of how decisions or actions could favor the outside interest
  6. Mitigation measures, including:
    • Specific management or operational controls in place
    • Steps taken to prevent bias or undue influence
    • How the University’s interests will be protected