Procedure for Conflict of Interest

A Conflict of Interest may be actual or perceived and generally occurs when, in the course of carrying out your university responsibilities, you take any action that may result in an actual or perceived benefit to yourself, or a related person or entity.

A perceived conflict is a situation where a reasonably well-informed person could properly have a belief that an actual conflict of interest exists, even when that is not the case. An example might be when people see that your family member is the vendor of services to the University, but you have no involvement in any decisions relating to the procurement of those services.

An actual conflict is a situation that provides a private benefit to yourself, or a related person or entity.

Actual conflicts may include, but are not limited to:

• taking part in or influencing a University decision that will result in a private benefit or benefit to a related person or entity (e.g. contracting with your own company or a relative's company for services to the University)
• using University resources for a private benefit or benefit to a related person or entity (e.g. contracting out the same work you were hired to do for the University, and using University resources and time to do the work)
• communicating confidential University information in order to obtain a private benefit or benefit to a related person (e.g. sharing your knowledge of RFP evaluation criteria with a friend so they can tailor their proposal)
• managing a related person (e.g. supervising your spouse/partner)

You are encouraged to review the definition of Conflict of Interest in the Code.

A Private Benefit means a financial or personal benefit to yourself, or to a person or organization with which you have a relationship.

Related person means an individual who is directly associated with you, and includes a parent, sibling, child, spouse or domestic partner.

While more specifically defined in the Code, generally a Related Entity means a corporation in which you have an ownership or are a director or officer, or a partnership in which you are a partner.

The Code and Procedures apply to Academic Staff Members, Appointees, Employees (including Postdoctoral Scholars), Volunteer Appointees and Student Employees.

If you are subject to the Procedure for Conflict of Interest and you fail to disclose an actual or perceived Conflict of Interest you may be subject to discipline, up to and including termination (depending on the provisions of the applicable collective agreement).

The Procedure for the Management of Related Persons outlines the steps that must be followed to manage a Conflict of Interest that occurs when an Academic Staff Member, Appointee, or Employee is involved in the ongoing employment of a Related Person.

As an Academic staff member, you have an ongoing obligation to disclose to your Dean, in writing, any time an actual or perceived Conflict of Interest arises.

You must disclose any actual or perceived Conflict of Interest in writing to your Dean, and may use the online Conflict of Interest Disclosure to do so. If the conflict relates to outside professional activity, hiring, promotion and tenure, it must be done in accordance with the applicable Collective Agreement provisions.

To complete a disclosure Navigate to myUCalgary > All about me > Employee Self Service > Conflicts of Interest and follow the steps to submit.

Academic Staff Members may have additional conflict of interest obligations and disclosure requirements in your role as Researcher, and if you are part of CSM.

The relevant information that needs to be disclosed is set out in the online Conflict of Interest Disclosure. At a minimum disclosure must include the following:

• A description of the circumstances that may be considered a Conflict of Interest
• A description of the Private Benefit(s) that may arise from a Conflict of Interest
• In the case of managing the employment of a Related Person,  the name of the Related Person and relationship to them as well as details of the type of reporting relationship (formal or functional).

You will only be asked to disclose information that is necessary in order for the Dean to assess and help you manage a perceived or actual Conflict of Interest.

• You may draft a proposed conflict of interest management plan for discussion with the Dean.

The information disclosed is collected in accordance with the Code of Conduct. Your Dean will use the information for the purposes of assessing, reviewing and managing an actual or perceived Conflict of Interest and will determine whether:

• there is a Conflict of Interest;
• the Conflict of Interest may be managed as an allowed Conflict of Interest; or
• the Conflict of Interest cannot be managed and steps need to be taken to eliminate the Conflict of Interest

If the Dean determines that there is no Conflict of Interest, the Dean will indicate in writing that there is no Conflict of Interest.

If there is a conflict, the Dean will work with you to create a conflict management plan or eliminate the conflict of interest.

If your Dean determines that there is a Conflict of Interest that may be managed, they will work with you to determine an appropriate conflict management plan. A conflict management plan sets out the steps you have to take to eliminate any perceived or actual private benefit as a result of a perceived or actual Conflict of Interest. 

Details of the conflict management plan will be documented and acknowledged by yourself and the Dean.

If your Dean determines that there is a Conflict of Interest that cannot be appropriately managed, your Dean will instruct you on the steps to take to eliminate the Conflict of Interest.

The steps taken to eliminate the Conflict of Interest will be documented and acknowledged by yourself and the Dean. 

If there is a Conflict of Interest on a committee struck under the TUCFA Collective Agreement pertaining to appointments, assessments, promotions and tenure or an applicant being assessed, the procedure will be governed by the Collective Agreement.

If a Dean has a financial or personal interest in the potential Conflict of Interest, the Conflict of Interest disclosure will be assessed by the appropriate Executive Leadership Team (ELT) member. 

The review can be delegated only if the Dean has a financial or personal interest in the potential Conflict of Interest being assessed. In those circumstances, the review would be done by the appropriate Executive Leadership Team (ELT) member. 

The Dean may delegate the implementation and ongoing monitoring of the conflict management plan.

No, Academic Staff Members who are authorized representatives (a Departmental Representative or Member of the Board of Directors) of the Faculty Association in accordance with the collective agreement do not have to disclose a Conflict of Interest on the basis of their activities, or roles, with the Faculty Association. 

Association membership does not create a Conflict of Interest within the scope of the Procedure for Conflict of Interest.

Yes. CSM academic staff members are required to complete the Conflict of Interest Disclosure every time a conflict arises and periodically at other times to ensure we remain compliant with accreditation standards for medical education programs.

All Employees (including Postdoctoral Scholars), Appointees and Volunteer Appointees (other than members of the Board of Governors or committees of the Board) must submit a Conflict of Interest Disclosure to their SLT leader. Navigate to myUCalgary > All about me > Employee Self Service > Conflicts of Interest and follow the steps to complete your disclosure.

Members of the Board of Governors or committees of the Board will submit a Conflict of Interest Declaration Form to the Board Chair. Please contact the Secretariat for more information.

If you have authority to approve expenditures (including purchasing/p-card), contracts, or the hiring of an individual on behalf of the University, you are required to submit a Conflict of Interest Disclosure annually and at any time a situation or circumstance arises that may result in a perceived or actual Conflict of Interest. Navigate to myUCalgary > All about me > Employee Self Service > Conflicts of Interest and follow the steps to complete your disclosure.

You may have additional conflict of interest obligations and disclosure requirements in your role as Researchers.

The relevant information that needs to be disclosed is set out on the Conflict of Interest Disclosure Form, and includes:

• A description of the circumstances that may be considered a Conflict of Interest
• A description of the Private Benefit that may arise from a Conflict of Interest
• In the case of managing the employment of a Related Person, the name of the Related Person and relationship to them as well as details of the type of reporting relationship (formal or functional).
• You may also propose a conflict management plan for discussion with your leader.

The information disclosed in the Conflict of Interest Disclosure is collected in accordance with the University of Calgary’s Code of Conduct.

If there is no conflict, your disclosure will not route to your leader for review, but will be available on your record should you or your leader wish to access it.

If you have a potential, perceived, or actual conflict, your SLT leader or Volunteer Manager will use your disclosure for the purposes of assessing, reviewing and managing an actual or perceived Conflict of Interest. 

Your SLT leader or Volunteer Manager will assess the situation or circumstances that may be considered a Conflict of Interest and determine whether:

• there is a Conflict of Interest;
• the Conflict of Interest may be managed as an allowed Conflict of Interest; or
• the Conflict of Interest cannot be managed and steps need to be taken to eliminate the Conflict of Interest

If there is a real or perceived conflict, your SLT leader or Volunteer Manager will work with you to create a conflict management plan or determine how to remove the conflict.

If your SLT leader or Volunteer Manager determines that there is a Conflict of Interest that may be managed, they will work with you to determine an appropriate conflict management plan, which will be documented on the conflict of interest disclosure and approved. A conflict management plan sets out steps you have to take to eliminate any actual or perceived Private Benefit as a result of a perceived or actual Conflict of Interest.

If your SLT leader or Volunteer Manager determines that there is a Conflict of Interest that cannot be appropriately managed, they will instruct you on the steps to take to eliminate the Conflict of Interest. 

The steps taken to eliminate the Conflict of Interest will be documented and acknowledged by yourself and the SLT leader on the Conflict of Interest Disclosure.

Your SLT leader or Volunteer Manager can delegate reviews only if they have a financial or personal interest in the potential Conflict of Interest being assessed. In those circumstances, the appropriate Executive Leadership Team (ELT) member will complete the review.

Your SLT leader or Volunteer Manager will administer or delegate the implementation and ongoing monitoring of the conflict management plan.

If you are subject to the Procedure for Conflict of Interest and you fail to disclose an actual or perceived Conflict of Interest you may be subject to discipline, up to and including termination (depending on the provisions of the applicable collective agreement).

No, if you are an authorized AUPE union steward or representative you do not have to disclose a Conflict of Interest on the basis of your activities, or roles, with the union. 

Union membership does not create a Conflict of Interest within the scope of this Procedure.

Yes, this procedure applies to all employees, appointees and volunteer appointees.