A Conflict of Interest Management Strategy outlines the scope and nature of actions, conditions or restrictions put in place to manage, mitigate or eliminate any actual, potential or perceived conflict of interest. The strategy is developed by the employee in close collaboration with their supervisor and other administrative officials, as warranted.
In some circumstances, simply declaring the perceived, potential or actual conflict, for the sake of transparency, may be sufficient to adequately mitigate or manage the conflict.
Other strategies may include:
- Restricted involvement in the situation or conflict
- Recruitment of an independent third party/management team to oversee part or all of the process
- Removal from situation or conflict
- Relinquishing a financial interest
- Establishment of a formal Management Plan
Management strategies will vary from less formal (conflict of interest scenarios that can be quickly mitigated) to more formal (complex scenarios requiring the use of a management plan – entailing periodic follow-up). Management strategy options may include, but not limited to:
- taking no further action because the potential for conflict is minimal or can be eliminated by disclosure and effective supervision;
- seeking the views of persons likely to be affected about the person continuing in the process;
- appointing an independent third party/management team to oversee the integrity of the process;
- refraining from the decision-making process in his/her University role when services or products are being selected involving the entity in which the employee may have an interest;
- forwarding any transactions requiring approval for payments to identified entities to a nominated oversight Manager for approval;
- disclosing the connection to those involved in making decisions to purchase products or services from the entity in which the employee may have an interest;
- informing impacted persons of the disclosure and the decision that there is no conflict, or that the potential for conflict is minimal;
- requesting the person to relinquish or divest the personal interest which creates the conflict, or to make other arrangements;
- removal of the person from the responsibilities or duties to which the conflict relates;
- making arrangements for members of boards and committees to recuse themselves from debate or decision on specific matters;
- seeking input from the Office of Research Compliance and Assurance or the Chief Compliance Officer; and
- agreeing on the triggers to escalate the situation for review of the management strategy.
When a conflict of interest arises in a committee situation and is disclosed by a committee member, the Chair (subject to the views of the meeting) may:
- ask the individual to leave while the item of business is discussed;
- ask the individual to abstain from voting and or discussion;
- allow the individual to participate in the discussion but withdraw from the meeting before the vote or abstain from voting; or
- allow the individual to stay but not participate in the debate
Committee member related conflicts are documented in the meeting minutes.