New Disclosure Requirements Under Policy 4.87

Revised Policy 4.87 – Emory Enterprise Conflict of Interest and Conflict of Commitment

Important updates have been made to Policy 4.87 – Emory Enterprise Conflict of Interest and Conflict of Commitment. These changes strengthen Emory’s commitment to transparency, accountability, and ethical conduct across the Emory community. 

Overview of the Revisions

  • Updates and enhances the definition of a conflict of interest 
  • Introduces new provisions and disclosure requirements for conflicts of commitment 
  • Requires all full-time staff to disclose any existing, perceived, or potential conflicts of interest
  • Requires all full-time staff to disclose and receive pre-approval for external activities such as second jobs, consulting, and board service 

Disclosure Requirement for Full-Time Staff

Starting December 2025, all full-time Emory University staff will be required to disclose any existing, perceived, or potential Conflicts of Interest (COIs) and/or Conflicts of Commitment. 

Disclosures will be submitted through the Insight system (new electronic disclosure system) that will be launched soon.

What You’ll Need to Disclose 

  • Financial and other interests that may represent a conflict of interest 
  • External activities such as second jobs, consulting engagements, or board service 

When to Disclose: 

  • Upon hire 
  • Annually 
  • Within 30 days of acquiring a new interest or identifying a potential conflict of interest 
  • Before engaging in an external activity that may present a conflict of commitment 

Existing Requirements Under Other Policies

The new requirements under Policy 4.87 do not replace obligations under other policies related to conflict of interest: 

  • Policy 7.7: Staff involved in research must also comply with the Financial Conflict of Interest in Research requirements. 
  • Policy 4.112: Principal Officers and Key Employees must continue to disclose in accordance with this policy. 
  • Emory Healthcare has its own conflict of interest and conflict of commitment disclosure process. If you are an Emory Healthcare employee and have questions about disclosure requirement, please reach out to the Emory Healthcare Office of Compliance. 

We’ll be sharing more detailed information regarding the disclosure requirements soon.