Conflict Management Guidance

A management plan is needed when a covered employee has a financial interest, relationship or other circumstance that has the actual, potential or perceived ability to impair their objectivity while performing university duties or participating in research at the university. Its purpose is to formulate a strategy to mitigate or eliminate risks to the employee’s objectivity. It outlines a plan of the steps that will be taken to manage an employee’s situation so that their objectivity will not be compromised while performing university duties and participating in research at the university.

The information that the covered individual provides on their annual COI disclosure will help the COI office identify whether a conflict of interest exists and, if it does, determine if a management plan is required. Therefore, it is critical that you complete your annual COI disclosure in a timely manner and ensure that the information disclosed is kept accurate and up to date. 

What are some examples of circumstances that may require a management plan?

Examples of circumstances that require disclosure and a management plan include but are not limited to:

• Participating in university research involving intellectual property (IP) owned by or contractually obligated to a business in which the individual or their immediate family has a consulting relationship, has a Significant Financial Interest (SFI), or holds an executive position (e.g., startup companies)
• Requiring students to purchase the textbook or related instructional materials of the employee or members of their immediate family, which produces compensation for the employee or family member
• Serving on the board of directors or scientific advisory board of an enterprise that provides financial support for the employee or their immediate family to conduct university research
• Having an SFI  in a business that: sponsors the employee’s research, or hires an NC State student whom the employee serves in a supervisory or mentoring capacity; or sells merchandise or services to the university while simultaneously working in the university business unit that makes purchasing decisions

Issues that may be addressed in a management plan include but are not limited to:

• Disclosing future developments in the external relationship to the institution
• Disclosing certain aspects of the relationship to third parties such as sponsors, journals, prospective donors
• Scope and nature of permissible activities (e.g., hiring university students in the outside endeavor or serving as principal investigator on projects funded by the external concern)
• Identification of the approvers of covered activities
• Acknowledgment of compliance with the law, regulation, and institutional policy
• Communication with government regulators (e.g., the FDA, EPA, USDA or CDC)

Familial relationships are not always widely known and must be disclosed in accordance with normal disclosure procedures. Research collaborations between an investigator and immediate family members with a significant financial interest may require further review and management by the conflict of interest office.

Familial or Amorous Relationships in relation to supervisory relationships and/or working together on a sponsored research project and the inherent fact or semblance of a conflict of interest created by an amorous or familial relationship should be disclosed and managed by the Office for Institutional Equity and Diversity (OIED) in order to avoid a potential violation of the OIED POL 04.20.06 – Interpersonal Relationships among Faculty, Staff, and Students.

For any questions regarding the existence of familial or amorous relationships at NC State, please contact the Office for Institutional Equity and Diversity at equalopportunity@ncsu.edu or 919-513-0574.

Management Plan Resources

Management Plan Template

For faculty with interests in an external entity that sponsors research or testing with the university.

Management Plan Declaration and Acknowledgment Form

Used to ensure that all research workers — including students, fellows, trainees, and visiting scientists — engaged in research under the conflicted employee’s supervision are notified of the COI, the existence of the management plan, and the names and contact information of the university officials with whom the researchers should address any concerns.

Examples of Publication Disclosure Statements for Conflict of Interest

Provides examples of public disclosure statements for use in publications, posters, meetings, symposiums or conferences for reporting financial relationships.