Conflicts of Interest (COI) and Conflicts of Commitment (COC)

Overview

Emory University expects all employees to avoid actual or perceived conflicts between their personal interests and their Emory responsibilities. These situations may be considered a Conflict of Interest (COI) or a Conflict of Commitment (COC) as defined in Policy 4.87: Conflict of Interest and Conflict of Commitment. 

The purpose of the policy is to ensure transparency, protect decision-making, and maintain public trust. Employees may not use Emory resources for private benefit. 

What is a Conflict of Interest (COI)?

A COI exists when personal interest or activity could affect—or appear to affect—an employee’s professional judgment or obligations to Emory. Specific circumstances, which may constitute a COI, include (but are not limited to), Financial Interests, Non-Financial Interests, and Gifts and 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. 

For full details, see Policy 4.87, Section 1. 

What is a Conflict of Commitment (COC)?

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. 

Generally, activities outside of Emory employment may be undertaken only if they do not:  

  • Require a time commitment that would disrupt the Individual’s ability to perform their Emory duties efficiently and effectively.  
  • Create a conflict of interest with the Individual’s status as an employee of Emory.  
  • Involve unauthorized use of Emory’s resources (human and financial), including but not limited to supplies, materials, equipment, facilities, services, or branding; Individuals may not use Emory property or facilities for any business, professional, or volunteer purpose not related to their position at Emory without the written approval of the Individual’s management.  
  • Imply or claim, explicitly or implicitly, Emory is responsible for these activities or the outcomes.  
  • Take away opportunities that would ordinarily be carried out directly by Emory. 

For details, see Policy 4.87, Section 2. 

Disclosure Requirements

Disclosure Requirement for Full-Time Staff

Starting December 1, 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 (the new electronic disclosure system). 

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  

How to Dislose

For information about how to disclose, please visit the How to Disclose page on our website.

Your Responsibilities

  • Disclose fully and on time. 
  • Follow any stricter rules your school or unit may have. 
  • When in doubt—disclose. 

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 requirements, please reach out to the Emory Healthcare Office of Compliance.  
  • Faculty are required to disclose in accordance with their school-specific requirements.

Resources & Contacts 

Related Policies & Links