University System of Georgia Updates Its Conflicts of Interest Policy

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To help maintain an ethical culture and preserve the public trust, the University System of Georgia (USG) recently made several revisions to the Conflicts of Interest and Conflicts of Commitment policy to provide additional detail and guidance to all employees in the USG system.

“While Georgia Tech encourages participation in approved outside activities, they must be appropriately disclosed and managed, as necessary, by the employee,” said Aisha Oliver-Staley, interim vice president for Ethics, Compliance, and Legal Affairs. “Understandably, it can be difficult to determine whether your activity should be disclosed and approved — the appropriate action isn’t always that obvious. This is why we recommend that you always ask the question and seek guidance up front, before participating in the activity.”

Key updates include the following:

USG employees (faculty and staff) involved in vendor selection or oversight may not be compensated or employed by such vendors.

The USG Chancellor must approve any outside activities for all 26 USG presidents and USG office employees. Each president, or appropriate

designee, is responsible for approving outside activities for their institution’s respective employees. If these employees are direct reports of the president or have the rank of vice president or higher, the institution’s president must forward the proposed outside activity approvals to the USG for review prior to giving final approval.

USG employees who accrue annual leave, including 12-month faculty with administrative duties, must take annual leave (commonly known as vacation time) for compensated outside activities including consulting.

Oliver-Staley said there are several things to remember when engaging in outside activities.

First, there is a difference between “consulting” and “professional services.” Consulting is participating in outside activities that relate to the employee’s area of expertise or responsibility as an Institute employee where a fee-for-service or equivalent relationship with a third party exists. Professional services consist of activities that are normally expected of faculty members and other professional staff members, such as participating in scholarly publication, peer review processes, or other activities performed on behalf of the Institute.

Second, only faculty who do not accrue annual leave may report consulting time for the time spent consulting. This has been redefined in Georgia Tech’s Employment Policy 5.4. Full-time faculty with administrative duties and full-time staff are not permitted to report consulting time. These employees are required to take annual leave when participating in approved outside activities.

Furthermore, outside activities for all employees, including faculty, must be disclosed and approved prior to participation in the activity. In general, participation in professional services does not need to be disclosed as a potential conflict of interest. Consulting activities, however, must be reported and approved prior to engaging in the activity. While all employees are required to review and confirm their conflict of interest file during the annual Integrity and Compliance Campaign, employees are also responsible for submitting and updating any activities as soon as the opportunity for the outside activity arises at any point in the calendar year. To disclose an activity, visit the Georgia Tech Conflict of Interest and External Activities Reporting Portal.

Lastly, questions and assistance regarding how to disclose and manage outside activity is available at COI@gatech.edu. Questions about conflicts of interest in business transactions can be sent to businesscoi@gatech.edu.

“This clarification is very timely for us here at Georgia Tech because it reminds us of our responsibilities as stewards of state resources,” said Oliver-Staley. “It provides an opportunity for us to reinforce our commitment to ethical conduct as individuals and as a community.”

The complete policy can be found on the USG website.