University Policy
Title
University of North Carolina at Chapel Hill Policy on Conflict of Commitment
Introduction
Purpose
This policy sets expectations for how employees at the University of North Carolina at Chapel Hill (“University” or “UNC-Chapel Hill”) balance their University Duties with External Professional Activities. It outlines when such activities may interfere with University duties, how potential conflicts are identified and reviewed, and how they may be addressed.
UNC-Chapel Hill supports appropriate external professional engagement when it enhances scholarship, teaching, service, or professional development. These activities must not compromise a Covered Individual’s ability to meet their University Duties that form an employee’s primary professional obligation.
This policy is not intended to govern matters which are addressed through applicable human resources policies.
Scope
This policy applies to:
- Faculty and EHRA non-faculty employees of UNC-Chapel Hill who are appointed at 0.5 FTE or greater; and
- Faculty and EHRA non-faculty employees of any FTE who are serving as senior or key personnel on a sponsored project.
SHRA employees are not Covered Individuals under this policy and are subject to the University of North Carolina at Chapel Hill Policy on Secondary Employment for SHRA Employees and other applicable policies.
Definitions
University Duties: Responsibilities tied to a Covered Individual’s role at UNC-Chapel Hill. These may include teaching, research, service, administration, supervision, and other assigned tasks or expectations.
Conflict of Commitment (COC): A situation in which a Covered Individual engages in External Professional Activities that compromise, may appear to compromise, or have the potential to compromise their ability to fulfill their University Duties.
Covered Individual: Any faculty and EHRA non-faculty employee of the University with an appointment of 0.5 FTE or greater are subject to this policy. In addition, any faculty or EHRA non-faculty employee of the University, regardless of FTE, is subject to this policy when serving as senior or key personnel on a sponsored project.
External Professional Activities: Paid or unpaid activities or commitments outside UNC-Chapel Hill that rely on a Covered Individual’s professional knowledge, experience, or abilities. Activities carried out under a University agreement as part of a Covered Individual’s University Duties are not classified as external activities.
External Professional Activities for Pay (EPAP): Paid external activities performed by faculty and EHRA non-faculty that require advance review and approval under the University of North Carolina at Chapel Hill Policy on External Professional Activities of Faculty and Other Professional Staff.
Management Plan: Written conditions or limitations issued by UNC-Chapel Hill designed to reduce or eliminate a Conflict of Commitment. The plan ensures the individual can meet their University Duties.
Senior or Key Personnel: Principal Investigator and any other person identified as senior/key personnel by the University in a grant application, progress report, or any other report submitted to a sponsor, regardless of sponsor type.
Policy
1. Policy Statement
Covered Individuals are expected to give priority to their University Duties. External Professional Activities, whether paid or unpaid, may provide professional benefits but must not interfere with the Covered Individual’s ability to meet their University Duties.
Conflicts of Commitment may arise from paid or unpaid External Professional Activities, including professional roles, leadership responsibilities, consulting, service, or other commitments that affect the time, effort, or availability required to meet University Duties. External Professional Activities for Pay are one category of External Professional Activities, but not all Conflicts of Commitment involve compensation.
This policy does not regulate personal or routine employment matters, which are addressed through applicable human resources policies and supervisory processes.
2. External Professional Activities That May Create Conflicts of Commitment
External Professional Activities that may create Conflicts of Commitment, include, but are not limited to, activities or circumstances that:
- Reduce the time or effort available to perform University Duties.
- Occur during work hours without prior approval.
- Create recurring or time-intensive obligations.
- Require significant ongoing leadership, managerial, or entrepreneurial involvement.
- Involve consulting, service, or professional practice that exceeds allowable time limits.
- Limit academic, research, or other scholarly activities performed by a Covered Individual on behalf of UNC-Chapel Hill.
- Involve agreements or engagements that constitute participation in a Malign Foreign Talent Recruitment Program.
- Require sharing or disclosing of UNC-Chapel Hill intellectual property, data, or resources without a University agreement.
- Involve non-monetary support from an external entity, such as personnel, facilities, equipment, or other resources, when that support creates obligations or time commitments that interfere with the Covered Individual’s University Duties.
- Have not been disclosed or approved when required.
3. Disclosure Requirements
Covered Individuals must disclose External Professional Activities that compromise, may appear to compromise, or have the potential to compromise their ability to meet their University Duties.
Disclosures are made through the processes outlined in applicable University policies or otherwise required by the University.
External Professional Activities for Pay (EPAP). Faculty and EHRA non-faculty disclose paid professional activities through the process established in the University of North Carolina at Chapel Hill Policy on External Professional Activities of Faculty and Other Professional Staff.
Unpaid or Informal External Activities. Covered Individuals must notify their supervisor when unpaid External Professional Activities may interfere with their University Duties. Supervisors determine whether additional review is needed based on the nature of the activity.
Conflict of Interest (COI) Disclosures. Covered Individuals must comply with annual disclosure requirements under the University of North Carolina at Chapel Hill Policy on Individual Conflicts of Interest in Research. When disclosed activities also raise Conflict of Commitment concerns, they are evaluated under this policy.
Changes to Previously Disclosed Activities. Covered Individuals must notify their supervisor or update disclosures when the time commitment, scope, or nature of an External Professional Activity changes in a way that compromises, appears to compromise, or has the potential to compromise their ability to meet University Duties.
4. Review and Management of Conflicts
Implementation of this policy occurs primarily at the supervisory or managerial level, based on the Covered Individual’s assigned workload, effort commitments, and professional responsibilities.
Supervisors review disclosed External Professional Activities to determine whether:
- The activity may proceed without limitation
- Conditions or limits are necessary to prevent a Conflict of Commitment
- The activity creates a Conflict of Commitment that cannot be managed
Supervisors review and record decisions related to External Professional Activities for Pay in the EPAP system. For other External Professional Activities, supervisors document decisions in accordance with unit or University practices.
Additional review may be required when an External Professional Activity involves:
- A country of concern.
- Intellectual property, equity, or licensing of University inventions.
- Sponsored research or effort-bearing commitments
- Participation in a Malign Foreign Talent Recruitment Program (MFTP).
For Covered Individuals whose employment or appointment is subject to immigration or visa restrictions, review by International Student and Scholar Services (ISSS) may be required to confirm that the activity is permitted under the individual’s immigration status.
Supervisors may consult with appropriate offices, including:
- School or Division Human Resources
- Office of Human Resources
- Conflict of Interest Office
- Sponsored Programs (especially for effort-bearing research commitments)
- Office of Technology Commercialization (when activities involve licensed intellectual property or equity interests)
- Science and Security Office (when it involves an international entity or individual)
- Associate Provost for Conflict of Commitment and EPAP
5. Management Plans
When a Conflict of Commitment can be reduced or eliminated, a Management Plan may be implemented. Management Plans may include adjustments to schedules or duties, limits on time commitments, defined boundaries for the activity, or periodic review.
Management Plans are developed collaboratively by the supervisor and the Covered Individual and approved at the appropriate level based on the individual’s role and responsibilities. Supervisors may consult with relevant University offices, as appropriate, when developing or implementing a Management Plan. Management Plans must be documented and updated as circumstances change.
6. Noncompliance and Enforcement
Covered Individuals are expected to comply with this policy, meet their University Duties, and adhere to approved Management Plans.
When a Covered Individual fails to meet these expectations, the supervisor will address the issue based on the specific facts and circumstances. Supervisors may consult with Human Resources, relevant compliance offices, or other University offices to determine the appropriate next steps, which may include clarifying expectations, adjusting work assignments, or revising the Management Plan.
Repeated or significant noncompliance may be addressed through the University’s applicable disciplinary or performance management processes for the Covered Individual’s role.
Related Requirements
External Regulations
University Policies, Standards, and Procedures
Contact Information
Primary Contact
Name: Gregory P. Copenhaver
Title: Associate Provost for COC and EPAP
Email: gcopenhaver@bio.unc.edu
Other Contact
Name: Quinton Johnson
Title: Assistant Vice Chancellor for Research Compliance
Email: quinton@unc.edu