COI and COC FAQs
Conflict of Interest (COI)
When is the annual disclosure period?
December 1st through February 28th.
Do I need to update my disclosure if my circumstances change mid-year or during the disclosure period?
Yes. You are required to update your disclosure within 30 days of any change in circumstances that may create a conflict of interest.
How do I access the Insight platform?
The Insight platform can be accessed at: https://emory.researchinsight.org/.
What is a Conflict of Interest?
A COI exists when personal interest or activity could affect—or appear to affect—an employee’s professional judgment or obligations to Emory.
Why do I have to disclose potential conflicts of interest?
Emory’s Policy 4.87 has been in place for a long time, and it has always required disclosure and approval of outside business ownership (and other potential conflicts of interest). The revised policy centralizes the disclosure process and adds requirements for disclosing other external activities that could give rise to both conflicts of commitment and conflicts of interest.
What will happen if a conflict of interest is identified?
If a conflict is identified, Emory will develop a management plan to mitigate the conflict.
What is the difference between COI and COC?
A Conflict of Interest (COI) occurs when an individual’s personal financial interests, relationships, or outside activities could improperly influence—or appear to influence—their professional judgment, decisions, or responsibilities at Emory. In contrast, a Conflict of Commitment (COC) arises when an individual’s outside activities, whether paid or unpaid, interfere with the time and effort they are expected to devote to their Emory responsibilities. While COI focuses on potential bias in decision-making due to personal interests, COC concerns the allocation of time and attention away from institutional obligations.
Conflict of Commitment (COC)
What is a Conflict of Commitment?
A COC arises when outside activities—paid or unpaid—interfere with an employee’s Emory duties. These activities may be compensated or not, including but not limited to, additional full or part-time employment, holding multiple concurrent jobs, consulting, or other contracting work, or serving on external boards that involve a commitment of time that may interfere with the Individuals’ fulfillment of their Emory responsibilities.
Why do I have to do disclose external activities?
Emory’s Policy 4.87 has been in place for a long time, and it has always required disclosure and approval of outside business ownership (and other potential conflicts of interest). Emory has just updated the scope of the policy to ensure outside activities do not involve a commitment of time that may interfere with the Individuals’ fulfillment of their Emory responsibilities or conflict with the obligations set forth in Emory’s standards of conduct and other policies.
What external activities am I required to disclose?
External activities include, but are not limited to:
- additional full or part-time employment (including self-employment)
- holding multiple concurrent jobs
- consulting or other contracting work
- or serving on external boards
If an external activity, compensated or not, requires more than 15 hours a week (on average) of time, then it must be disclosed and approved prior to it being undertaken.
Additionally, serving as a director, officer, advisory board member, or manager in any other entity, organization, or business that does or seeks to do business, or competes for business, with Emory must be disclosed and approved prior to engagement.
Do I have to disclose unpaid external activities?
Yes. Unpaid activities, such as volunteer board service or consulting, must be disclosed if they require 15 or more hours of commitment (on average) per week. Additionally, serving as a director, officer, advisory board member, or manager in any other entity, organization, or business that does or seeks to do business, or competes for business, with Emory must be disclosed and approved prior to engagement.
What type of external activities must be disclosed?
All outside employment, business ownership, consulting, board service, and other professional activities—paid or unpaid—that could interfere with your Emory responsibilities or create a conflict of interest.
Do I need to submit a disclosure for approval prior to applying for a job?
No, not necessarily. However, you must submit a disclosure and receive approval before accepting or engaging in any outside employment.
How does this requirement impact employees who already have outside jobs or who already own businesses?
Employees with existing outside employment or business interests must disclose these activities and obtain approval to continue them under the updated policy.