Conflict of Interest Support and Education

Conflict of Interest Disclosure Form

Conflict of Interest Management Plan

The revisions to the COI Policy and Procedure were undertaken as part of the scheduled review of the governing documents and to advance recommendations from the 2019 report Responding to Sexual Violence, Harassment and Discrimination at the University of Manitoba: A Path Forward, that called for strengthened conflict of interest governance, transparency, and accountability across the university.

Key Changes

The revised COI Policy and Procedure strengthen and clarify the university's conflict of interest framework in several important ways:

• Clarifying that conflicts of interest may arise in teaching, service, employment, research, supervisory, evaluative, and decision-making responsibilities, and that conflicts may be actual, potential, or perceived.
• Introducing definitions of Intimate Relationship and Prohibited Relationship, and expressly prohibiting relationships with students where instructional, supervisory, or evaluative authority exists.
• Expressly requiring that other Intimate Relationship conflicts, including those arising in the employment context, be disclosed and managed through the conflict of interest process where possible.
• Clarifying that Prohibited Relationships cannot be managed through the Conflict of Interest Policy and Procedure and must be referred to the Office of Human Rights and Conflict Management under the Sexual Violence Policy and related procedures.
• Strengthening and clarifying language around disclosure and review requirements through prompt written disclosure, updated disclosures when circumstances change, written determinations, and documented management plans.
• Improving alignment with research compliance and external funder requirements through consultation with the Office of Research Services where appropriate.
• Clarifying implementation, accountability, and disciplinary consequences for breaches in accordance with applicable collective agreements, contracts, bylaws, and University policies and procedures.

As part of these efforts, the Sexual Violence Policy and the Disclosure and Complaints Procedure were revised to align with these changes.

What Is Not Changing

The revisions do not change the university's fundamental expectations regarding conflicts of interest.

Faculty, staff, and students continue to be responsible for identifying and disclosing conflicts of interest. The existence of a conflict of interest does not necessarily prevent an activity from proceeding. In many situations, conflicts of interest can be appropriately managed through disclosure, review, and implementation of a management plan. Academic and administrative leaders will continue to play an important role in reviewing disclosures and managing conflicts of interest within their areas of responsibility.

What Is a Conflict of Interest  

A conflict of interest is a situation in which the private interests (financial or personal) of a university community member compromise or have the appearance of compromising their independence and objectivity in performing obligations to the University.

Conflicts can be;

• actual (where a conflict exists),
• potential (where circumstances could develop into a conflict), or
• perceived (where a reasonable person might think a conflict exists). 

The University of Manitoba recognizes that conflicts of interest arise naturally from engagement inside and outside the university. They are not inherently unethical or indicative of wrongdoing. Rather, they are situations requiring disclosure and proper management to maintain public trust in the university's teaching, research, and service mission 

Key Terms You Need to Know 

Financial Interest: The receipt or expectation of receiving anything of monetary value, including salary, consulting fees, honoraria, equity (shares or options), security or ownership interests, and intellectual property rights such as patents, copyrights, or royalties.

Personal Interest: Any non-financial benefit a person or related party receives or expects to receive, whether related to their workplace or otherwise. 

Related Party: A family member (spouse, child, parent, sibling, grandparent, aunt, uncle), other person living in the same household, or any person with whom you share an intimate relationship, financial interest, or personal interest. 

Executive Position: Any position responsible for the operation or management of a business or organization. 

External Activities: Any activity outside your scope of work with the University. 

Prohibited Relationship: An intimate relationship entered into with a student at a time when you have instructional, supervisory, or evaluative authority over that student—this type of relationship cannot be managed and constitutes a breach of policy. 

Major Categories of Conflicts of Interest 

The University identifies several major categories where conflicts of interest commonly arise:

• Teaching and Evaluation Conflicts occur when your responsibility to instruct and evaluate students fairly and objectively is or appears to be impeded or compromised.
• Business and Financial Conflicts arise when you have influence over decisions about proposed or existing relationships between the University and a business in which you or a related party has a financial interest, personal interest, or holds an executive position.
• Research Conflicts necessitate careful attention to maintain public trust in research results. These arise when an individual or related party holds a financial or personal interest in the outcomes, conducts research for organizations in which they or a related party have interests, assesses products from companies where interests exist, or utilizes university resources for external business activities.
• Misuse of Position and Information Conflicts involve using your university position to solicit students, colleagues, government agencies, or private companies for external activities, or using non-public information acquired through your university relationship for external activities.
• External Commitments Conflicts occur when obligations to boards or advisory positions with external organizations interfere with or compromise your obligations to the University.
• Relationship-Based Conflicts arise when you participate in, influence, or make decisions about instruction, supervision, evaluation, discipline, employment, funding, advancement, or research activities of someone with whom you have a Personal Interest, or is a Related Party, or with whom you have an intimate relationship. 

Examples of Conflicts of Interest by Category 

The following table provides various examples across different conflict of interest categories which can assist in the recognition of situations that require disclosure.

Some of these examples may be manageable conflicts of interest, while others may not. Whether a conflict of interest can be managed depends on the specific facts and the available mitigation measures. 

What to Do If You Identify a Conflict

As soon as you become aware that a conflict of interest exists, you must disclose it in writing on the Conflict of Interest Disclosure Form

(Appendix A, Part 1 of the Conflict of Interest Policy)

Use these instructions to complete the “Conflict of Interest Disclosure Form” when you are disclosing your own actual, potential, or perceived conflict of interest. Before completing the form, review the University of Manitoba Conflict of Interest Policy and applicable procedures, as the form requests confirmation that you have done so.

Step-by-step instructions (complete every item)

1. Complete Contact Information 

2. Policy review confirmation: Check Yes to confirm you reviewed the Conflict of Interest Policy and applicable procedures before submitting the form. At this stage, you may also wish to contact your Initial Reviewer to let them know about your conflict of interest and that your disclosure form will be provided to them.

3. Explain the nature of any Conflict(s) of Interest that has, will, or may be perceived to arise: Describe the situation clearly and factually. Include (a) what the outside/private interest is, (b) what your University role/decision is, (c) where they overlap, and (d) timing (when it started/when it may arise). If you have more than one conflict, list each separately (Conflict 1, Conflict 2, etc.).
   Include: names of organizations involved; your role (employee, consultant, board member, owner, researcher, etc.); and whether the conflict is actual, potential, or perceived.
   Example wording: “I serve as an unpaid board member of [Organization]. In my University role, I participate in decisions about partnerships that could involve this organization. This creates a perceived conflict of interest.”

4. List all Persons (including Students and trainees) who may be affected by the Conflict of Interest: List individuals or groups whose work, supervision, evaluation, funding, purchasing, hiring, or research participation could be influenced (or appear influenced). Use names where appropriate; if names are not yet known, describe the group (e.g., “students in COURSE 1230,” “trainees in my lab,” “committee members,” “research participants in Study X”).

5. Provide details concerning the nature and/or value of any real or perceived advantage or benefit  to you or a Related Party: Describe any direct or indirect benefit and, if possible, estimate its value or range (e.g., royalties, consulting fees, honoraria, gifts, equity, travel support, employment opportunities, non-financial benefits such as enhanced reputation or access). Identify whether the benefit is to you or a related party and how it connects to your University duties.

6. List all persons… who should be made aware of the Conflict of Interest: Identify those who may need to know for transparency and appropriate oversight (as applicable): your supervisor/department head, committee chair, co-investigators, students/trainees, journal editors, funding agencies, conference organizers, collaborators, procurement contacts, or others connected to the decision/activity.

7. Prior external disclosure (YES/NO): Answer whether you have already fully disclosed the actual or potential conflict in writing to an external research funder (public/private), the Research Ethics Board (REB) and/or other University authorities.

   • If YES: attach a copy of the written disclosure(s) to the form submission (as the form instructs).

   • If NO: leave no attachments for this item and continue to the next questions.

8. Explain any benefits that may be derived by the University by managing the Conflict of Interest: Describe legitimate University benefits that could be preserved if the conflict is transparently managed (e.g., continuation of valuable research, partnerships, commercialization opportunities, student opportunities, community impact) while maintaining integrity and public trust.

9. Do you think this conflict can be managed? (YES/NO): Select YES if you believe practical steps can reduce the risk (or appearance) of bias; select NO if you believe it cannot be adequately mitigated. If unsure, choose the option that best reflects your current assessment and explain your reasoning in the text boxes that follow.

10. If “YES”: Explain the steps you propose to manage the Conflict of Interest: Propose concrete mitigation actions tailored to the situation. Typical management measures include:

    • Recusal: step out of decisions, evaluations, procurement, hiring, admissions, grading, authorship decisions, or funding decisions connected to the conflict.

    • Independent oversight: assign an independent decision-maker/supervisor; add an arm’s-length reviewer to committees.

    • Transparency/disclosure: disclose the conflict to affected parties (e.g., trainees, collaborators, committees, editors, funders) as appropriate.

    • Role separation: adjust reporting lines or duties to remove supervisory/evaluative authority over related parties.

    • Data/publication safeguards: independent data analysis, protocol registration, or third-party monitoring where relevant.

    • Documentation: keep written records of recusals and decisions.

11. Explain how the proposed Conflict of Interest may, or may be seen to, impact your judgment: Describe the specific decisions or responsibilities that could be influenced (or appear influenced) and the type of risk (bias in evaluation, preferential treatment, financial gain, pressure on trainees, compromised research integrity, perceived lack of fairness). Keep it factual and focused on the connection between your interest and your University responsibilities.

12. Other applicable information: Add any context that will help an Initial or Secondary Reviewer understand the situation (e.g., dates, contracts/agreements, whether you supervise or evaluate anyone involved, whether University resources are used, steps already taken, or any urgency/timeline).

13. Ongoing duty to update: The form states you must promptly report in writing any change in circumstances that could alter the conflict or its management. Make sure you have a way to monitor changes (e.g., new role, new funding, changed reporting relationships).

14. Signature and Date: Sign and date the form (and keep a copy for your records). Attach any required supporting documents (such as prior written disclosures) before submission.

Quick tips (to avoid delays)

• Be specific about who is involved, what your role is, and which University decisions/activities overlap with the private interest.

• Include related parties where applicable and describe indirect benefits, not only direct payments.

• If you select YES to prior written disclosure, remember to attach the disclosure(s).

• Your management plan should be actionable (named role/office/committee, clear steps), not only a general statement like “I will be careful.”

Purpose 

This supporting document is intended to assist supervisors, managers, department heads, directors, deans, and other individuals acting as an Initial Reviewer under the University's Conflict of Interest Policy and Procedure. It provides practical guidance on recognizing conflicts of interest, responding to disclosures, maintaining appropriate records, and supporting ongoing compliance.

The Conflict of Interest Policy is founded on the principles of recognition, disclosure and management. Supervisors and managers play an important role in fostering a culture where potential conflicts are identified early, disclosed appropriately, and addressed in a fair, consistent, and transparent manner.

It will also act as a quick reference resource to help Initial Reviewers build practical Conflict of Interest (COI) Management Plans using Appendix B of the University’s Conflict of Interest Procedure.

Responsibilities of Supervisors and Managers

As an Initial Reviewer, you are responsible for:

• Creating an environment in which employees feel comfortable raising potential conflicts of interest.
• Receiving and reviewing conflict of interest disclosures.
• Consulting with the employee regarding the circumstances of the disclosed conflict.
• Assessing whether the conflict can be managed, requires additional review, or cannot be managed.
• Developing and recommending appropriate conflict management measures where applicable.
• Forwarding recommendations and supporting documentation to the appropriate Secondary Reviewer.
• Maintaining records relating to disclosures and management plans.
• Monitoring compliance with approved conflict management plans.
• Promptly addressing changes in circumstances that may affect a previously disclosed conflict of interest.

Receiving a Disclosure

When an employee submits a disclosure:

Step 1: Acknowledge Receipt

Confirm receipt of the disclosure and advise the employee that the matter will be reviewed in accordance with the University's Conflict of Interest Policy and Procedure.

Step 2: Gather Relevant Information

Discuss the disclosure with the employee to understand:

• The nature of the interest or relationship.
• The employee's University responsibilities.
• Any actual decision-making authority involved.
• The likelihood that the interest could affect, or appear to affect, the employee's objectivity.
• Any additional information needed to assess the situation.

Step 3: Determine Whether Immediate Interim Measures Are Required

In some circumstances, temporary measures may be necessary while the review is underway, such as:

• Recusal from decision-making.
• Reassignment of approval authority.
• Temporary changes to reporting relationships.
• Independent review of decisions.

Help for Initial Reviewers: Developing Conflict of Interest Management Plans 

Role of the Initial Reviewer 

• Review the disclosure and identify the key risks.
• Consult and collaborate with the disclosing individual about the conflict of interest, the situation and options for managing.
• Consult with other units, such as the Office of Research Services, Partnerships, Knowledge Mobilization and Innovation Office; Faculty of Graduate and Postdoctoral Studies, where appropriate.
• Assess the conflict of interest (see below).
• Where a conflict of interest can be managed, draft a conflict of interest management plan using the template that fits the level of risk and is workable day-to-day.
• Send your recommendation (and the draft plan, if needed) to the Secondary Reviewer.

Best-Practice Principles 

• Treat disclosure as a positive step.
• Conflicts of interest are situational, not disciplinary by default.
• Make the plan clear, measurable, and easy to audit (who does what, by when).
• Plans should protect integrity while enabling legitimate University activities, where possible. 

When preparing your recommendations

Step 1: Describe the Conflict Clearly (Appendix B) 

• Briefly describe the activity, interest, or relationship that creates the conflict.
• Note the individual’s University role, what decisions they can influence or how they may benefit.
• Indicate whether the conflict is actual, potential, or perceived.
• Avoid judgmental language; focus on facts (avoid labels or assumptions).

Step 2: Assess the Risk Factors 

• Does the individual have authority or decision-making responsibility over students, staff, funding, grading, research, or procurement?
• Is there a power imbalance (e.g., supervisor/trainee, instructor/student)?
• Could the individual (or a related party) gain a personal or financial benefit?
• Is there personal or financial benefit to the discloser or a related party?
• Would a reasonable person perceive bias or unfairness?
• Is this tied to a high-stakes decision (e.g., hiring, promotion, tenure, admission, grades, contract award, or resource allocation)?

Other factors that can increase risk:

• How close/dependent the relationship is
• Size of the interest/benefit (financial or non-financial)
• How often and for how long the situation occurs
• Level of transparency/likelihood of public scrutiny
• Impact on vulnerable people (e.g., students, trainees, patients, participants)
• Ability to influence the process design (e.g., criteria, scoring, access to information)

The purpose of the assessment is not to determine wrongdoing, but to evaluate whether the safeguards are required to protect the interests and reputation of both the employee and the University.

Step 3: Select Appropriate Management Techniques 

• Recusal: Have the individual step out of the decision, evaluation, or discussion.
• Independent oversight: Assign an arm’s-length reviewer/supervisor to make or verify the decision.
• Role separation: Reassign supervisory, evaluative, or approval tasks to someone else.
• Transparency: Share the disclosure with affected parties when appropriate (and document that it happened).
• Monitoring: Set check-ins or reporting so someone confirms the plan is being followed.

Other Specific Techniques Available (as needed)

• Written boundaries/scope: Specify what the individual may and may not do (e.g., may provide factual information only; may not recommend, rank, approve, sign, or negotiate).
• Approval and sign-off routing: Identify an alternate decision-maker/signer (e.g., expense approval, HR/Procurement sign-off, department head approval).
• Documentation requirements: Define what must be documented (e.g., recusal statement, minutes, decision rationale, retained correspondence, audit trail).
• Disclosure timing and audience: Clarify when and to whom disclosures must be made (e.g., committee meetings, consent forms, procurement file, publications).
• Restricted access controls: Limit access to sensitive information (e.g., gradebook entries, applicant files, pricing, unblinded data, contract drafts).
• Blinding or independence safeguards: Use blinded grading, third-party data analysis, independent reference checks, or independent consent/recruitment processes where appropriate.
• Oversight structures: Add an independent member, create a subcommittee, and confirm quorum without the conflicted individual where applicable.
• Training/acknowledgement: Require regular review of the COI procedure and written acknowledgement of responsibilities.
• Implement communication rules: Set a documented point of contact; avoid one-on-one communications with vendors/candidates/participants; use documented channels; avoid using University IT systems(including UM email) for external business (and vice versa).
• Financial controls: Set thresholds for independent review, segregation of duties, and (where applicable) benchmarking/competitive quotes.

Step 4: Set Review and Monitoring Requirements 

• Set a review date (at least annually) and define triggers for re-review (e.g., role change, new contract, relationship change).
• Name who will check compliance (and what they will check).
• Require prompt written updates if anything changes (role, relationship, contract, funding, etc.).

When a Conflict Cannot Be Managed 

• Some conflicts of interest (e.g., prohibited relationships or inseparable financial interests) can’t be managed even with conditions.
• In these cases, recommend that the activity not proceed and flag it to the Secondary Reviewer right away.

Key Drafting Tips 

• Be concrete: name roles, actions, dates, and decision points.
• Avoid vague language (e.g., “as needed, try to”).
• Make sure each control directly reduces the specific risk you identified.
• Write it so someone else could follow it if you were away.

Record Keeping Responsibilities

Appropriate record management is critical to ensuring consistency, accountability, and compliance.

Supervisors and managers should maintain records of:

• Conflict of interest disclosure forms.
• Supporting documentation provided by the employee.
• Notes of discussions regarding the disclosure.
• Recommendations submitted to the Secondary Reviewer.
• Approved conflict management plans.
• Any updates, amendments, or reviews of management plans.
• Documentation confirming compliance monitoring.

Records should be stored securely and only shared with individuals who require access for purposes of administering the Policy, implementing management measures, complying with legal obligations, or meeting University business requirements. The University will maintain conflict of interest records in accordance with applicable laws and records retention requirements.

Monitoring and Follow-Up

Conflict management is an ongoing process.

Supervisors should:

• Periodically review active management plans.
• Confirm that management measures remain appropriate.
• Address any concerns regarding compliance.
• Require updated disclosures when circumstances change.
• Escalate concerns where a conflict appears no longer manageable.

Employees have a continuing obligation to promptly update disclosures whenever circumstances change or a new conflict arises. 

Annual Performance Review Discussions

Annual performance and development discussions provide an important opportunity to reinforce employees' obligations under the Conflict of Interest Policy and Procedure.

As part of the annual review process, supervisors should:

1. Remind employees of their obligation to identify and disclose actual, potential, and perceived conflicts of interest as they arise.
2. Discuss whether the employee has:
   • External activities,
   • Board appointments,
   • Consulting activities,
   • Financial interests,
   • Research relationships,
   • Personal relationships, or
   • Other circumstances that could give rise to a conflict of interest.
3. Review any conflict disclosures made during the preceding year and confirm:
   • Whether the circumstances remain unchanged;
   • Whether management measures remain effective;
   • Whether updates to existing disclosures are required; and
   • Whether any additional conflicts should be disclosed.
4. Document that the discussion occurred as part of the annual performance review process.

The annual review does not replace the requirement for immediate disclosure. Employees remain responsible for disclosing conflicts as soon as they become aware of them. The annual review serves as an additional compliance checkpoint and an opportunity to ensure that existing management plans remain current and effective.

Examples of situations, risks, and management strategies

Although every conflict of interest is different and unique, the examples below reflect situations, risks, and management strategies that have come up at the University.

Quick Reference Resource

1. Receive the Disclosure

☐ Acknowledge receipt of the disclosure.

☐ Review the disclosure for completeness.

☐ Determine whether any immediate interim measures are required (e.g., recusal, reassignment of authority).

2. Assess the Situation

Ask:

☐ Is there an actual conflict of interest?

☐ Is there a potential conflict of interest?

☐ Could a reasonable person perceive a conflict of interest?

☐ Could the employee's personal, financial, research, or external interests affect their University responsibilities?

☐ Is additional information required?

Remember: the goal is not to determine misconduct, but whether the situation requires management. 

3. Determine the Appropriate Response

☐ No conflict identified.

☐ Conflict identified but no management measures required.

☐ Conflict identified and management measures required.

☐ Conflict appears unmanageable and requires escalation.

4. Develop a Management Plan (if required)

Consider whether the following are needed:

☐ Recusal from decisions.

☐ Alternate supervision or evaluation arrangements.

☐ Independent review or monitoring.

☐ Restrictions on access to information.

☐ Alternate hiring, promotion, purchasing, or research processes.

☐ Disclosure requirements.

☐ Other tailored safeguards.

Ensure expectations, responsibilities, and review dates are documented. 

5. Refer to Secondary Reviewer

☐ Prepare written recommendation.

☐ Attach supporting documentation.

☐ Submit recommendation to Secondary Reviewer.

☐ Implement decision once received.

6. Maintain Records

Retain:

☐ Disclosure form.

☐ Supporting documents.

☐ Assessment notes.

☐ Recommendation.

☐ Decision of Secondary Reviewer.

☐ Management plan.

☐ Monitoring records.

Store records securely and restrict access to those with a legitimate need to know. 

7. Monitor and Follow Up

☐ Communicate management requirements.

☐ Monitor compliance.

☐ Review periodically.

☐ Update management measures when circumstances change.

☐ Remind employee of ongoing disclosure obligations.

8. Annual Performance Review Check

During each annual performance review:

☐ Remind the employee of their obligations under the Conflict of Interest Policy and Procedure.

☐ Ask whether any new external activities, appointments, financial interests, research relationships, or personal relationships may create a conflict.

☐ Review all existing disclosures and management plans.

☐ Confirm whether circumstances have changed.

☐ Determine whether updates or new disclosures are required.

☐ Document that the discussion occurred.

Key Message: Annual review discussions are a compliance checkpoint, not a substitute for immediate disclosure when a conflict arises. Employees must disclose actual, potential, and perceived conflicts as soon as they become aware of them. 

Supervisor Reminder

Recognize → Discuss → Assess → Manage → Document → Monitor → Review Annually

When in doubt, encourage disclosure and seek guidance rather than allowing a potential conflict to go unaddressed. 

Understanding the Secondary Reviewer Role 

The Secondary Reviewer holds a critical decision-making position in the University of Manitoba's Conflict of Interest (COI) review and management process. Upon receipt of the Initial Reviewer's written recommendation and proposed management plan (when applicable), the Secondary Reviewer conducts an independent assessment to determine whether the proposed research or university activity can proceed.  

The Secondary Reviewer must evaluate whether the proposed management strategies adequately address the identified conflict(s). Decisions at this level directly affect research and innovation activities, the University’s reputation, students and instructors (for example, through teaching, supervision, and grading), and compliance with legal and regulatory obligations. 

Secondary Reviewer Decision Framework 

Under section 2.4.1 of the Conflict of Interest Procedure, the Secondary Reviewer has several options when considering the Initial Reviewer’s written recommendation. 

Receiving and Reviewing Initial Reviewer Recommendations 

The Secondary Reviewer's evaluation process begins upon receipt of the Initial Reviewer's written recommendation submitted under the University’s Conflict of Interest Procedure Section 2.3.2 . This documentation must include the person's original disclosure, the Initial Reviewer's assessment, and, when applicable under Section 2.3.1(b), a proposed management plan.  

The Secondary Reviewer should verify the completeness of the submission, ensuring all required elements are present before commencing substantive review. 

The review should examine whether the Initial Reviewer has accurately characterized the nature and severity of the conflict of interest, whether proposed management strategies align with institutional policies and regulatory requirements, and whether the plan's monitoring and oversight provisions are sufficiently robust. 

Evaluating Management Plan Adequacy 

Assessing whether a proposed management plan adequately addresses an identified conflict of interest requires several considerations. The Secondary Reviewer must determine if the management plan's scope comprehensively covers all aspects of the disclosed conflict of interest, including financial interests, external relationships, and whether the suggested strategies are appropriate and proportional. 

Management strategies should be specific, measurable, and enforceable rather than vague aspirational statements. Effective plans include clear timelines, designated oversight responsibilities, and explicit compliance requirements. Any Disclosure requirements should specify the audiences who must be informed (students, collaborators, research participants, funding agencies) and the precise language to be used. 

The feasibility assessment examines whether proposed restrictions can realistically be implemented given the person’s role, available resources, and operational constraints.   

Decision-Making Chart 

Approval Decisions: When to Proceed

The Secondary Reviewer’s decision under Conflict of Interest Procedure section 2.4.1 will depend on whether the disclosed activity is permissible as disclosed, whether a management plan is required, and whether any proposed management plan adequately addresses the identified conflict of interest. In general, the Secondary Reviewer may: approve the activity with no further action, approve the Initial Reviewer’s proposed management plan, approve the plan with modifications, or determine that the activity cannot proceed.

Option 1: Approve with no further action

The Secondary Reviewer may determine that the proposed activity or conflict of interest is permissible as disclosed and that no further action is required. This applies where the Initial Reviewer has correctly assessed that no actionable conflict exists, or where the disclosed external activity or financial interest presents minimal risk, does not relate to the person’s university responsibilities, or reflects a common professional activity with limited conflict potential.

Option 2: Approve the Initial Reviewer’s proposed management plan

Where a conflict of interest has been identified but can be appropriately managed, the Secondary Reviewer may approve implementation of the Initial Reviewer’s proposed management plan. This is appropriate when the proposed strategies address the identified risks, are feasible to implement, align with University requirements and relevant best practices, and include appropriate monitoring provisions where required. 

Option 3: Approve with modifications to the management plan

Where the Initial Reviewer’s proposed management plan provides a reasonable foundation but requires strengthening or clarification, the Secondary Reviewer may approve the plan with modifications, as permitted under section 2.4.1(b). Modifications should be proportionate to the nature and severity of the conflict and should clearly identify what additional safeguards, restrictions, oversight, or reporting requirements are required. Factors to consider when developing the plan can be found in the Initial Reviewer Supporting Document.

Common modifications include: 

• Strengthening disclosure requirements to ensure transparency with additional stakeholders, such as requiring written notification to graduate students or postdoctoral fellows about faculty conflicts when the trainees may be involved in related external activities.
• Enhanced monitoring provisions may involve increasing review frequency from annual to semi-annual or quarterly, appointing an independent data steward to oversee research integrity, or requiring the initial reviewer to receive periodic compliance certifications.
• Restrictions on use of university resources often need clarification or expansion, specifying that university resources such as equipment or laboratory space, cannot support the external activity without formal facilities use agreements and appropriate cost recovery.
• Student and trainee protection modifications frequently prohibit faculty from directly supervising students or postdoctoral fellows employed by companies in which the faculty member holds financial interests, instead requiring appointment of a non-conflicted co-advisor.
• Purchasing and procurement restrictions prevent conflicted individuals from making sole-source justifications or participating in vendor selection processes for entities in which they have financial interests 

The Secondary Reviewer should clearly record the reasons for each change, so the Person understands what is required, why it is required, and how compliance will be checked. 

Option 4: Determine that the activity cannot proceed

Where the conflict of interest cannot be adequately managed, the Secondary Reviewer must determine that the proposed research or university activity is not permissible under section 2.4.1(c). This applies where the nature or magnitude of the conflict is such that no reasonable management plan would sufficiently protect institutional integrity, research integrity, students or trainees, decision-making processes, or the University’s reputation. It also applies where the relationship is a “Prohibited Relationship” under the Policy.

Monitoring, Oversight, and Documentation 

Approved management plans require ongoing monitoring to ensure continued compliance and effectiveness. The Secondary Reviewer, in collaboration with the Initial reviewer and the Person making the disclosure, should establish clear monitoring responsibilities, timelines, and documentation requirements at the time of plan approval. When management plans extend beyond one year, Procedure Section 2.5.2 requires annual updates and continued monitoring throughout the duration of the conflict of interest. Further information on this can be found in the Initial Reviewer Supporting Document.

1. What is a conflict of interest?

A Conflict of Interest arises when a person’s private interests (financial or personal) compromise, or appear to compromise, their independence or objectivity in carrying out their University responsibilities. Conflicts may be actual, potential, or perceived.

A conflict is about the situation, not the integrity or intent of the individual.

2. Who is required to follow the Conflict of Interest Policy and Procedures?

The Policy applies broadly to all “Persons” engaging in University activities, including:

• employees (all groups),
• faculty,
• students (graduate and undergraduate),
• post‑doctoral fellows,
• Senate members,
• individuals with adjunct, nil‑salary, or committee appointments, and
• others involved in activities under the authority or control of the University.

3. What kinds of interests can create a conflict?

Conflicts can arise from:

• Financial interests (e.g., consulting fees, equity, honoraria, royalties);
• Personal interests (non‑financial benefits);
• Related party interests (e.g., interests held by family members or intimate partners);
• External activities that intersect with University responsibilities; and
• Intimate relationships, particularly where teaching, supervisory, evaluative, or decision‑making authority exists.
• Conflict of Commitment, such as when external professional activities (for example, outside employment, consulting, or volunteer roles) interfere with, or reasonably appear to interfere with a person’s ability to meet their University obligations (such as teaching, research, supervision, service, or administrative duties). While it may not involve a direct financial or personal benefit that affects a specific decision (conflict of interest), it is a time and priority conflict that can still require disclosure and management.

4. What is the difference between actual, potential, and perceived conflicts?

• Actual conflict: The interest currently affects decision‑making.
• Potential conflict: The interest could reasonably affect future decision‑making.
• Perceived conflict: A reasonable observer could think the interest affects decision‑making, even if it does not.

All three must be disclosed.

5. When do I need to disclose a conflict of interest?

You must disclose as soon as you become aware that a conflict exists or may exist.

You must also update your disclosure promptly if:

• circumstances change, or
• a new conflict arises.

Disclosure is a continuing obligation.

6. How do I disclose a conflict of interest?

Disclosures must be made in writing using the form attached as Appendix A to the Procedure and submitted to your Initial Reviewer.

If the matter involves a graduate student or post‑doctoral fellow, a copy must also be sent to the Dean of the Faculty of Graduate and Post‑Doctoral Studies.

7. Who is my Initial Reviewer?

The Initial Reviewer is normally the person to whom you report (for example, your department head, supervisor, or unit head).

If the Initial Reviewer has a conflict of interest in the matter, you must disclose directly to the Secondary Reviewer, who will assume the Initial Reviewer’s role for that disclosure.

8. What happens after I disclose?

The Initial Reviewer will:

• assess the situation in consultation with you;
• consult the Office of Research Services if the matter involves research; and
• recommend one of the following to the Secondary Reviewer:
  • no action required;
  • a management plan to address the conflict; or
  • that the activity is not permissible due to the conflict.

9. What is a conflict management plan?

A management plan outlines specific measures to prevent the conflict of interest from affecting University activities. Depending on the situation, measures may include:

• disclosure of the interest;
• recusal from decisions;
• reassignment of supervisory or evaluative duties;
• alternate reporting structures;
• independent oversight or monitoring; or
• modification or termination of external activities.

Plans must be followed once approved. Failure to follow a management plan will be considered a breach of the policy and may result in discipline.

10. Who makes the final decision?

The Secondary Reviewer considers the Initial Reviewer’s recommendation and may:

• approve the activity with no further action;
• approve and implement a management plan (with or without modifications); or
• determine the activity cannot proceed because the conflict cannot be managed.

Decisions are provided in writing.

11. What if I disagree with the decision?

You may refer the matter to the Conflict of Interest Committee for review if you are unsatisfied with the Secondary Reviewer’s decision.

12. What role does the Conflict of Interest Committee play?

The Committee:

• reviews referred matters;
• determines whether conflicts can be managed; and
• implements management plans where appropriate.

If the Committee determines a conflict of interest cannot be managed, the activity must not proceed. Committee decisions are final.

13. Are intimate relationships treated differently?

Yes. A Prohibited Relationship-an intimate relationship with a student where instructional, supervisory, or evaluative authority exists-cannot be managed and is not permitted.

Prohibited Relationships:

• must be disclosed; and
• are also addressed under the Sexual Violence Policy and Disclosures and Complaints Procedure.

Other intimate relationships that create conflicts of interest (including in employment contexts) must still be disclosed and may be managed depending on circumstances.

14. Do research funders have additional requirements?

Yes. Some external research funders have their own conflict of interest requirements, including stricter timelines or reporting obligations.

Where funder requirements are more stringent than University procedures, those stricter requirements must be followed.

There may also be disclosure requirements to the Research Ethics Board. 

15. What happens if someone fails to disclose a conflict?

Failure to disclose, failure to comply with a management plan, or entering a Prohibited Relationship may result in disciplinary action, consistent with:

• applicable legislation,
• collective agreements or contracts, and
• University bylaws, policies, and procedures.

Consequences differ depending on whether the person is an employee, student, or holds another role.

16. Are conflict of interest records confidential?

Generally, yes. Conflict of interest records are kept in accordance with:

• applicable privacy laws, and
• University records retention schedules.

However, information may be disclosed where required for other University processes, by law, or by external research funders.

17. Why does the University require disclosure?

Disclosure protects:

• the integrity and reputation of individuals;
• public trust in the University; and
• the fairness and credibility of University decision‑making, teaching, research, and service.

The goal is transparency and appropriate management, not punishment.

When in doubt, disclose early and ask questions. Early disclosure allows conflicts to be assessed and managed appropriately and helps protect both individuals and the University.