Conflict of Interest

Faculty and staff must request and receive prior approval for participation in additional work commitments. Supervisors will assess whether the additional commitment represents a conflict of commitment, a situation in which the employee has overcommitted to multiple employers or entities. This is an employee-initiated disclosure, routed to their supervisor for approval. Faculty must disclose outside activities (i.e., consulting and outside employment) using the Disclosure and Management System. Staff must disclose additional employment (at or outside of Virginia Tech) using form P-36   in accordance with Policy 4070.  For faculty approvers, please see the Approving Faculty Outside Activity Disclosures section on the FAQ page for more information.

Graduate students on an assistantship must disclose additional employment to Virginia Tech in the manner prescribed in the Graduate Catalog. Contact the Graduate School with questions.

For employees engaged in sponsored research with the level of responsibility similar or equivalent to a principal investigator, financial interests that reasonably appear related to the Investigator’s institutional responsibilities must be disclosed in the Disclosure and Management System. The RCOI Program will notify you if you meet the definition of an Investigator for this purpose.

An employee must disclose through the Disclosure and Management System if the employee or their immediate family member a) holds >3% of the total equity in or b) receives >$5,000 in annual payments from the business. For employees who disclose in the Disclosure and Management System in the context of numbers 1 or 2 above, this requirement only applies if there will be a purchase of goods or services from the entity. This is an employee-initiated disclosure.

Initial disclosures must be submitted before the additional work commitment, sponsored research, or university contract begins. Disclosures in the Disclosure and Management System must be updated within 30 days of any changes and renewed annually, as needed.

The purchase of goods and services by the university from a business or entity owned by a university employee, or by a member of the employee’s immediate family, is a prohibited conflict of interest under state law. The conflict exists even if the purchase is being made by a department/unit other than the employee’s home department. An exception to this prohibition can be granted in certain circumstances if disclosure requirements to the university and other conditions are met. Single onetime purchases valued at $500 or less are exempt from this requirement.

Contact your department head or supervisor (faculty) or your supervisor or HR (staff) with questions about additional work commitments.

Contact the RCOI Program at mailto:coi@vt.eduwith questions about Investigators, financial interests related to sponsored research and sponsored projects, or technical concerns involving the Disclosure and Management System.

Contact Procurement at mailto:procurement@vt.eduwith questions about financial interests related to purchasing contracts/transactions.