Body
University Policy
Title
University of North Carolina at Chapel Hill Policy on Conflicts of Interest for University Employees
Introduction
Purpose
The University of North Carolina at Chapel Hill (“UNC-Chapel Hill” or “University”) expects employees to act with integrity and in the best interest of the University. Conflict of Interest (COI) arises when Interests held by an employee or a member of their Immediate Family may compromise their Institutional Responsibilities, may create the potential for compromise, or may give the appearance of compromise. Transparent disclosure and appropriate management support sound decision-making and protect the University’s mission and public trust.
This policy sets the baseline for what constitutes COI for all University employees. Some employees must also follow additional COI rules required by federal or state law, research sponsors, or University Unit-specific standards.
Scope
This policy applies to all University employees, including faculty, staff, administrators, and anyone acting on the University’s behalf. It is relevant across academic, administrative, operational, financial, procurement, and contracting activities.
Definitions
Conflict of Interest: Any situation in which a University employee’s Interest may compromise, may involve the potential for compromising, or may appear to compromise their objectivity in performing Institutional Responsibilities. An Employee has a COI when they, or any member of their Immediate Family has an Interest in an activity that may affect decision-making with respect to their Institutional Responsibilities.
Immediate Family: University employee's spouse, dependent children, or any person cohabitating with the University Employee, sharing mutual responsibility for each other's welfare and financial obligations.
Institutional Responsibilities: An individual's professional responsibilities on behalf of the University. These may include, but are not limited to, research, research consultation, teaching, professional practice, institutional committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.
Interest: A personal, professional, financial, or other connection held by a University employee or a member of their Immediate Family that could reasonably be seen to influence the employee's judgment, decisions, or actions related to Institutional Responsibilities. Interests may include financial relationships such as ownership or income, or non-financial roles such as leadership positions, professional affiliations, or personal relationships connected to University activities.
- Examples of Financial Interests: Income from outside entities, ownership or equity, intellectual property rights, or gifts that support the employee’s professional activities. Financial Interests do not include University salary, income from U.S. academic or government-sponsored lectures or advisory roles, or income from investment vehicles where the employee does not control investment decisions.
- Examples of Personal Interests: Family or close personal relationships with individuals or entities doing business with the University, leadership or advisory roles with outside organizations, volunteer or civic activities that overlap with University responsibilities, or commitments that may interfere with fulfilling Institutional Responsibilities.
University Unit: A school, division, department, center, institute, office, or any other organizational entity within the University that has supervisory, administrative, academic, research, financial, or operational authority. The term includes both academic units and administrative units responsible for managing University programs, resources, and personnel.
Policy
1. Policy Expectations
University employees are required to act in good faith, avoid personal gain at the University’s expense, and disclose any Interest that could compromise or appear to compromise their Institutional Responsibilities. COI may arise across academic, administrative, operational, financial, procurement, and contracting activities and must be managed appropriately, or where required, avoided entirely.
If, in the course of performing your Institutional Responsibilities, you have decision-making authority that directly affects a UNC-Chapel Hill employee who is also an Immediate Family member, you must disclose this relationship to the COI Office. The COI Officer will then determine the appropriate steps to manage the conflict.
2. Areas Where Conflicts of Interest May Arise
COI may occur in many areas of University work. The examples below highlight the areas where they often appear and the expectations for handling them.
Procurement and Contracting Conflicts
Employees involved in purchasing or contracting are expected to support fair, unbiased University decisions by keeping their own Interests, and those of their Immediate Family, separate from the process. This applies to anyone involved in vendor evaluations, writing specifications, negotiations, contract awards, or oversight of related work.
When federal funds support a purchase or contract, the University must follow the federal procurement standards in 2 CFR 200.318. These rules require employees to act impartially and not take part in the selection, award, or administration of a contract if they have a real or apparent COI.
North Carolina General Statute §14-234 also restricts conflicts in contracting. Employees and their spouses may not receive direct financial benefit from a University contract they help create or influence. They may not influence others involved in the contract when they or their Immediate Family have an Interest in the outcome. They may not accept rewards or the promise of future employment tied to contract decisions.
Employees must disclose any Interest connected to a vendor or contractor. If a conflict exists, the employee must not take part in decisions or activities related to that contract. Conflicts that violate N.C.G.S. §14-234 cannot be managed and must be eliminated.
These statutory requirements are implemented in University purchasing rules, including the 1211 Policy on Avoiding Vendor Conflicts of Interest, which applies the prohibitions in N.C.G.S. §14-234 to University procurement activities.
Other Conflicts of Interest
Employees must avoid situations where Interests could influence or appear to influence decisions in areas such as:
- Research design, conduct, oversight, or reporting
- Supervision of students, trainees, or staff when personal relationships may affect judgment
- Allocation or use of University space, funds, or other resources
- Service on search committees or review panels where the employee or their Immediate Family has an Interest in the outcome
- Any other hiring decisions where the employee’s Immediate Family or Interests are involved
- Leadership or advisory roles in external organizations that intersect with University responsibilities
- Professional activities or affiliations that could affect objectivity in University work
Teaching, curriculum decisions, or academic evaluations that may be affected by external Interests
- Use of confidential or non-public information for personal benefit
- Activities or time commitments that interfere with fulfilling Institutional Responsibilities
3. Disclosures
Disclosure Requirements
Employees must notify the COI Office at COI@unc.edu when they believe they have a COI or when a situation arises that could reasonably be viewed as a COI. This includes any situation where an Interest held by the employee or their Immediate Family may influence or appear to influence the Employee’s Institutional Responsibilities. Employees must contact the COI Office as soon as they become aware of a change, and before participating in any related University decisions or activities.
Review Process
The COI Office has the authority to review all reported situations to determine whether an Interest held by an employee or their Immediate Family creates an actual COI, a potential COI, or the appearance of a COI in relation to the employee’s Institutional Responsibilities. During the review, the COI considers:
- The connection between the Interest and the employee’s Institutional Responsibilities
- The nature and extent of the Interest
- The employee’s role and level of authority in the relevant University activity
- The potential impact on University decision making, operations, research, or contracting
- Any state, federal, or sponsor requirements that apply
- Whether the Interest involves procurement or contracting governed by N.C.G.S. §14-234
For conflicts involving procurement or contracting subject to N.C.G.S. §14-234 , the COI Office coordinates its review with Purchasing Services and other required authorities.
When a reported COI involves supervision, hiring, evaluation, or other employment actions affecting an Immediate Family member or close personal relationship, the COI Office coordinates its review with Human Resources to ensure consistency with applicable employment policies, including the University’s Policy on Nepotism and Interpersonal Relationships.
Employees must provide additional information if requested by the COI Office.
Determinations
After completing the review, the COI Office may determine that:
- No conflict exists
- A conflict exists but can be managed with appropriate conditions
- The conflict is impermissible and must be eliminated
The COI Office communicates determinations to the employee and, when appropriate, to supervisors or other University officials who must help implement the decision.
4. COI Management
When the COI Office determines that a conflict can be managed, it develops a written management plan in consultation with the employee and the supervisor as appropriate. The plan outlines the conditions necessary to protect the integrity of University decision-making. COI management may include one or more of the following measures.
- Recusal from decisions or activities involving any matter in which the employee or a member of their Immediate Family has an Interest that could compromise or appear to compromise their judgment. Recusal may include stepping away from discussions, specification development, evaluations, contract decisions, or supervision of related work. Recusal is not required for routine administrative tasks, and simply abstaining from a vote does not resolve a conflict unless an exception under N.C.G.S. §14-234 applies.
- Modification of duties, such as reassigning decision-making authority or shifting supervisory responsibilities.
- Independent oversight or review by a neutral party who monitors decisions, documentation, or activities affected by the conflict.
- Restrictions on use of University resources that relate to the external Interest creating the conflict.
- Disclosure requirements to collaborators, trainees, students, sponsors, or others when transparency is needed or required by law or sponsor rules.
- Training or reporting obligations, such as periodic status updates or documentation requested by the COI Office.
The COI Office coordinates with Human Resources and the employee’s supervisor when a management plan involves changes to supervision or duties covered by HR policy.
Management plans involving changes to supervision, job duties, or employment conditions are implemented in coordination with the employee’s supervisor and Human Resources, as applicable.
Conflicts governed by statute or other binding legal requirements, including certain procurement and contracting conflicts under North Carolina General Statute §14-234, are not eligible for management and must be eliminated.
Employees are responsible for complying with all conditions in their plan. Supervisors must help ensure that management plan is implemented.
Monitoring and Updates
The COI Office may monitor compliance with the management plan by reviewing documentation, requesting status updates, or meeting with the employee or supervisor.
Employees must notify the COI Office when circumstances change, including changes in their role, duties, or Interests, or when any condition in the management plan is no longer applicable. Management plans remain in effect as long as the conflict exists.
5. Misuse of Information
University employees must not use confidential or non-public information gained through their University role for personal benefit or to benefit others, including, but not limited to, Immediate Family. University employees must not pursue business opportunities that the University may reasonably be expected to pursue unless the University formally declines them.
6. Reported Concerns
University employees who suspect a violation of this policy must report concerns confidentially to a supervisor or through the Carolina Ethics Line. Employees who report in good faith are protected from retaliation under the University’s Whistleblower Policy.
7. Noncompliance and Enforcement
Violation of this policy, including failure to disclose a relationship covered by this policy and failure to adhere to an approved Conflict Management Plan, may subject an individual to disciplinary action, up to and including termination of employment, in accordance with relevant University policies.
The COI Office may waive or reduce University administrative sanctions when noncompliance results from a good-faith error.
Consequences under N.C.G.S. §14-234
Violations of N.C.G.S. §14-234 may result in:
- A Class 1 misdemeanor
- Contracts being void unless approved under statutory exceptions
Related Requirements
External Regulations
University Policies, Standards, and Procedures
Contact Information
Primary Contacts
Name: Quinton Johnson
Title: Assistant Vice Chancellor for Research Compliance
Unit: Office of the Vice Chancellor for Research (OVCR)
Email: quinton@unc.edu
Name: Raha Khademi
Title: Director of the Conflict of Interest Office, Conflict of Interest Officer
Unit: Conflict of Interest Office, OVCR Research Compliance services
Email: khademi@unc.edu