|
Policy Number:
HR.012
Effective Date:
May 1, 2026
Last Revised/Approved Date:
April 30, 2026
Approved By:
President
Responsible Office/Unit:
General Counsel/COI Officer/Human Resources
1. Purpose
The Conflict of Interest Policy ensures that all decisions and actions undertaken on behalf of Life University are conducted with integrity and in the best interests of the institution. The policy applies to faculty, staff, administrators, contractors, scholarship and grant committee members, alumni, governing board members, and all individuals acting on behalf of or in the interest of the University, and is designed to prevent personal, financial, or other interests from compromising the University’s mission, ethical standards, or commitment to education.
This policy establishes a framework for identifying, disclosing, and addressing actual, potential, or perceived conflicts of interest. Individuals should disclose conflicts of interest and commitment when carrying out their external and internal University education, research, scholarship, or service responsibilities. All external relationships, domestic and international, should be transparent and disclosed in a manner consistent with applicable requirements, including federal and state laws, regulations, and agency guidance, as well as Life University’s policies and procedures.
2. Scope
This policy applies to all faculty, staff, administrators, contractors, scholarship and grant committee members, alumni, governing board members, and all individuals acting on behalf of or in the interest of the University.
3. Policy Statement
Conflicts, perceived conflicts, and potential conflicts must be reported by the faculty, staff, administrators, contractors, scholarship and grant committee members, alumni, governing board members, and all individuals acting on behalf of or in the interest of the University.
4. Definitions
Definition of Conflict of Interest
A conflict of interest occurs when an individual’s personal, financial, or professional interests could improperly influence, or appear to influence, their decisions or actions on behalf of Life University. These include actual conflicts (those that directly involve competing interests); potential conflicts (those that could develop into a conflict); and perceived conflicts (those that appear improper, even if no actual conflict exists). Examples include:
- Financial Interests: Ownership or investment in businesses or entities that contract with the university.
- Personal Relationships: Family, romantic, or close personal relationships with employees, students, vendors, or contractors where decisions may appear biased.
- External Activities: Participation in external employment, consulting, or other business ventures that interfere with university responsibilities.
- Gifts and Benefits: Accepting substantial gifts, payments, or other benefits from individuals or entities associated with university decisions.
- Academic Conflicts: Situations that compromise academic integrity or fairness, such as favoritism in grading, hiring, or research collaborations.
- Research Conflicts: External entities that may be related to research or technology transfer when that entity: Sponsors the research(proposal, subcontract), supplies equipment, materials or services as part of the sponsored research agreement (subcontract, purchasing); commercializes a product for which the research is to evaluate and/or develop further (intellectual property); may be impacted financially by the research or technology transfer agreement (management position
5. Procedures
Policy Guidelines
- Duty to Disclose
All individuals covered under this policy must promptly disclose any actual, potential, or perceived conflicts of interest to the Office of Human Resources. Annual conflict of interest disclosure forms must also be completed.
- Conflict of Interest Review Process
The conflict of disclosure form has four general phases:
- Initial review by The Office of Human Resources
- Review by the president’s cabinet [or designee, or COI officer], excluding any involved parties;
- Determination and Response by the Office of Human Resources of any suspected conflicts
- Annual Review of disclosure and monitoring of any conflict management plans
The Office of Human Resources conducts an Annual Review of active conflict of interest and will apply the criteria below:
1) Determining whether the conflict is actual, potential, or perceived and whether it interferes or compromises any University education, research, scholarship, or service responsibilities
2) For those conflicts where interference or compromise is determined, creation of a management plan to manage the conflict to mitigate or eliminate the conflict. (e.g., recusal from decisions, modification of responsibilities)
3) Creation of management plans for situations where it has been determined that an actual, potential, perceived conflict exists. This includes any individual responsible for research design, conduct, or reporting.
Conflict of Interest (COI) management plans will be reviewed at least annually to confirm the following:
- The identified actual, potential, or perceived conflict of interest continues to exist.
- The individual involved continues to hold a role related to the research activity or the external entity.
- The individuals responsible for monitoring and managing the conflict of interest remain appropriate and properly assigned.
- Required disclosures of the conflict have been made in publications, presentations, reports, or other applicable materials, as appropriate.
As part of this COI process, the conflicted individual plays a key role in answering questions to update the disclosure with pertinent information about the conflict situation. The individual may be asked for additional details regarding the disclosure but will not participate in decisions regarding the matter. The conflicted individual will receive guidance from the Office of Human Resources on managing any conflicts.
- External Engagements
Faculty, staff, administrators, contractors, scholarship and grant committee members, alumni, governing board members must obtain prior written approval before engaging in external employment or activities that could conflict with their university responsibilities. Review of external engagements will follow the COI review process.
- Prohibition of Improper Influence
Individuals must not use their position at or with Life University to influence decisions in ways that result in personal gain or unfair advantage for themselves or related parties.
Confidentiality
Disclosures and related evaluations will be handled confidentially, consistent with the university’s commitment to transparency and its obligation to protect institutional interests.
Annual Disclosure and Certification
All faculty, staff, administrators, contractors, scholarship and grant committee members, alumni, governing board members must annually affirm their understanding of this policy and disclose any conflicts of interest or certify the absence of such conflicts.
Violations of Policy
Failure to disclose conflicts of interest or comply with mitigation measures may result in disciplinary action, including but not limited to reassignment, suspension, or termination of employment or position with the university.
6. Related Policies and References
Conflict of Interest Disclosure Form
Name:
[Full Name]
Position/Role:
[Your position or role in the organization]
Date:
[MM/DD/YYYY]
1. Acknowledgment
I have read the Life University Conflict of Interest Policy set forth above and agree to comply fully with its terms and conditions at all times during my service as a member of the Life University community. If at any time following the submission of this form I become aware of any actual or potential conflicts of interest, or if the information provided below becomes inaccurate or incomplete, I will promptly notify in writing my supervisor and update my COI disclosure with the Office of Human Resources. I acknowledge my responsibility to disclose any situation that may create an actual, potential, or perceived conflict of interest between my personal interests and the interests of Life University.
2. Disclosures
Please answer the following questions:
a. Financial Interests:
Do you or any immediate family members have a financial interest in any company, organization, or entity that does business with or competes with Life University?
☐ Yes
☐ No
If “Yes,” please provide details:
[Details of the financial interest]
b. Relationships:
Do you have any personal or familial relationships with individuals or entities that may influence your ability to act impartially in your role?
☐ Yes
☐ No
If “Yes,” please provide details:
[Details of the relationship]
c. Other Conflicts:
Are there any other situations, commitments, or responsibilities that may conflict with your duties to Life University?
☐ Yes
☐ No
If “Yes,” please provide details:
[Details of other conflicts]
3. Certification
I certify that the information provided in this disclosure is complete and accurate to the best of my knowledge. I agree to notify Life University promptly if any new potential conflicts of interest arise during my involvement.
Signature:
[Your Signature]
Date:
[MM/DD/YYYY]
8. Review Cycle
Will be reviewed annually.
9. Contact Information
The Office of Human Resources
Christian Fuller, General Counsel
|