During UT’s review of Outside Interest Disclosure Forms, outside interests are sometimes identified that may present a real or perceived conflict with an employee’s roles and responsibilities to UT. Not all conflicting interests are unethical or impermissible. Also, while this process can be concerning, we hope by providing information about the process for conflict mitigation, it can be positively viewed by employees and supervisors.
When identifying an outside interest that creates a potential or real conflict, the employee and/or their supervisor are contacted for additional information. The information is reviewed by a case-by-case approach.
Conflicts can be managed through a variety of ways, such as independent reviewers, reassignment of responsibilities, modifying a research plan or other methods to reduce or minimize the effects of an actual or potential conflict. An appropriate plan monitor, usually the individual’s supervisor, is appointed to ensure compliance with the plan.
Supervisors should contact the campus conflict committee chair to discuss management plan development for applicable employee situations identified during their reviews.
Examples of mitigation activities include:
- Placing parameters around consulting agreements when the company does business with UT.
- Limiting purchasing sources when those sources are owned all or in part by an employee within the department, college, center, etc.
- Ensuring Non-compete justifications are not being entered into by a department where an employee has ownership.
- Placing additional levels of review/approvals when purchasing from a company where an employee has an affiliation.
- Creating appropriate lines of supervision and approvals when family work within the same department.
- Public announcements of conflicts (e.g., when presenting or publishing the research)
- Appointment of an independent monitor capable of taking measures to protect the design, conduct, and reporting of research against bias resulting from the conflict
- Modification of the research plan
- Retaining memorandum to employee personnel file to document review
- Substituting a researcher
- Changing a university employee’s or researcher’s responsibilities
- Disqualifying a research investigator from participation in all or a portion of the research
- Reducing or eliminating the conflict (e.g., sale of an equity interest); or
- Severing the relationship(s) creating a conflict.