Conflicts of Interest Quick Guide

GENERAL INFORMATION FOR ALL INDIVIDUALS

UNC Charlotte policies related to Conflicts of Interest

You can access the current UNC Charlotte Policy for Conflicts of Interest and Commitment at: http://legal.uncc.edu/policies/up-101.24

The UNC Charlotte Conflict of Interest policy is a Chancellor-approved policy specific to the Charlotte Campus. It is based on a combination of federal regulations (Code of Federal Regulations, 42 CFR Part 50 and 45 CFR Part 94), UNC General Administration Policy on Conflict of Interest and Commitment and applicable North Carolina State statutes.

The procedures, processes and mechanisms for conflict disclosure, evaluation, and management can be found at: https://legal.uncc.edu/policies/up-101.24-procedures

Additional policies that relate to the Conflict of Interest policy:

Conflict of Interest definition

Conflict of Interest relates to situations in which financial or other personal considerations may compromise, may involve the potential for compromising, or may have the appearance of compromising an employee’s objectivity in meeting University duties or responsibilities, including research activities. - UNC General Administration Policy Manual.

Conflict of Commitment definition

A Conflict of Commitment occurs when an employee’s external activities interfere with their employment responsibilities to UNC Charlotte.

Applicability of UNC Charlotte Conflict of Interest Policy

All Faculty, EHRA, and designated SHRA staff must complete a Conflict of Interest (COI) disclosure at least annually as a condition of employment. 

In addition, anyone responsible for the design, conduct, or reporting of a proposed or funded research project must disclose certain financial interests as they relate to that specific project.  In some cases, non-UNC Charlotte persons participating in research at this campus will have to comply with UNC Charlotte COI Policy. Please see: Information for Researchers.

Annual disclosure process

The Annual COI disclosure must be completed each year by October 1st, and must be completed even if you do not have anything to disclose.  The disclosure covers current activities and interests, and those from the previous 12 months. You are responsible for submitting an updated disclosure within 30 days of discovering a new reportable financial interest or activity.

Near the beginning of the Fall semester, a reminder of the annual disclosure requirement will be sent, followed by periodic direct email reminders.

The Annual disclosure is accessed with your NinerNET username and password at the following link: uncc.myresearchonline.org/air/.

The AIR (Activities, Interest and Relationships) system serves as a portal to manage all disclosure and request forms related to Conflicts of Interest and Commitment. You may initiate new Conflict of Interest disclosures or External Professional Activity for Pay notifications through this system (these forms will be combined into one in the next upgrade to the system). You may also view any previously submitted form and its current review status.

What to do if you cannot access the online system.

If you or any personnel experience technical issues within the AIR system, you can call the COI Manager at 704-687-8270. If you have trouble with your NinerNET login, you should contact UNC Charlotte IT Services (7-5500).

If you have trouble connecting to the system, try waiting 15-30 minutes and try again. In previous years the system would get overloaded after the initial disclosure announcement due to too many people trying to connect to the server.

Process in the event a conflict of interest is identified.

The COI Manager seeks to be a resource to all individuals across campus. Conflicts of interest can exist even if no improper acts have occurred and potential conflicts of interest are often a natural consequence of certain research and teaching activities (i.e., commercializing intellectual property, working with industry, or authoring instructional materials). The COI Manager and appropriate University offices and committees will provide guidance as to how to manage personal and financial interests and relationships appropriately, pursuant to University Policy.

When an individual responds affirmatively to certain fields on a Conflict of Interest disclosure form, additional questions will appear on the screen. These questions prompt the individual to explain or provide more details in regards to the “Yes” answer. The completed disclosure is reviewed by the COI Manager who makes an initial determination regarding the existence of a conflict, or contacts the individual if additional information is needed. The COI Manager then works with the discloser and their Department Head and/or COI Administrator to determine if an actual conflict of interest exists. For actual conflicts of interest, the Department Head and COI Administrator help the COI Manager develop a written management plan.

Confidentiality of Conflict of Interest disclosures

The information that you provide on a COI disclosure is considered part of your personnel file and will be considered confidential unless other treatment is required or allowed by law or regulation. Information will be shared internally as necessary and pursuant to the review procedures. Please see the Confidential Status of Financial Disclosure Forms section of the University’s Conflict of Interest Procedures.

Consequences of not disclosing personal or financial interests related to University responsibilities

The consequences of failing to disclose one’s interests, as they relate to one’s University duties, can vary depending on the circumstances. Please see the section on Policy Breaches; Reporting Obligations in the Procedures regarding University’s Policy on Conflicts of Interest and Commitment.

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