Disclosure Guidance

Conflict of Interest

Full-time staff must disclose financial interests, non-financial interests, and gifts or gratuities as defined below:

  • Financial interests: Ownership, investments, or paid relationships with entities doing or seeking business with Emory or entities that compete with Emory. Any ownership in a privately held entity or more than 5% ownership in a publicly traded company is considered a financial interest. 
  • Non-financial interests: Serving as an uncompensated 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. 
  • Gifts or gratuities: Accepting meals, tickets, travel, entertainment, or other benefits from vendors. Limited exceptions exist for modest, infrequent items (≤ $150 per occurrence, ≤ $300 per year), professional conference meals, or certain travel connected to Emory’s interests. Cash, gift cards, and vendor-paid travel are never acceptable.

Conflict of Commitment

Full-time staff are required to disclose external activities that may represent a conflict of commitment. The external activities must be disclosed and approved prior to engaging in them.

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.

Examples of what does and does not need to be disclosed:

External Employment

  • A full-time Emory employee takes on a part-time retail job requiring 20 hours per week—must be disclosed and approved because it’s more than the 15-hour threshold.
  • A staff member runs a personal consulting business on weekends, averaging 10 hours per week—disclosure may not be required unless it exceeds 15 average per week hours or the person does or seeks to do business with Emory.

Volunteer Activities

  • An employee volunteers as a board member/treasurer for a nonprofit organization that contracts with Emory—must be disclosed and approved, regardless of the weekly time commitment.
  • A staff member volunteers at a local charity for 5 hours per week—does not require disclosure.

External Service as Director, Officer, Advisory Board Member, or Manager

  • A staff member serves as a director for an organization that competes with Emory’s services—must be disclosed and approved before engagement.