Procedures for Administering Annual Disclosure Requirements for Selected Staff

  1. The list of staff from whom disclosures are required annually, and their assigned senior administrators for purposes of disclosure form collection and/or secondary review, will be maintained by the Senior Vice President for Corporation Affairs and Governance and updated periodically.
  2. The Senior Vice President for Corporation Affairs and Governance shall distribute disclosure forms to individuals on the list annually.
  3. Completed forms are to be submitted promptly to the disclosing employee's supervisor.
  4. Each supervisor is responsible for noting the affiliations that are disclosed and discussing them with the employee. If there are no disclosures which present a conflict or appear to present a conflict, the supervisor should sign the form and forward it to the assigned senior administrator. If there are disclosures which present a conflict or appear to present a conflict, the supervisor is responsible for working with the employee to determine whether a management plan is warranted (see #5 below), signing the disclosure form to acknowledge that it has received supervisory review, and forwarding it to the assigned senior administrator for that employee. Forms that disclose affiliations are required to receive secondary review and signature by the assigned senior administrator or, when the assigned senior administrator is also the employee's supervisor, by the assigned senior administrator's supervisor.
  5. When an affiliation that might pose a conflict is disclosed, the supervisor must determine if a management plan to address the situation must be developed. Determination as to whether a management plan is required should involve consultation between the disclosing staff member and the supervisor, and may include consultation with the supervisor's senior officer, the Vice President and General Counsel, the University Auditor, and/or other officers. If there is an actual conflict, these same individuals may be consulted to determine an appropriate management plan to resolve the conflict. The management plan should be attached to the disclosure form and then sent to the assigned senior administrator or other secondary reviewer for signature.
  6. Senior administrators, as assigned by the Senior Vice President for Corporation Affairs and Governance, are responsible for collecting disclosure forms and, if warranted, management plans within their divisions and forwarding them to the Office of Corporation Affairs and Governance.
  7. The Department of Human Resources shall maintain employees' disclosure forms and related management plans, and the University Auditor shall periodically monitor the file to ascertain that the selected staff have complied with the disclosure requirements of this policy.
  8. After the University Auditor's review, disclosure forms and related management plans shall be maintained in employees' individual personnel files in Human Resources.