Conflict of Interest & Commitment Program

COIC Program (last updated: Sept 2025)

University Compliance in the Office of Audit, Risk, and Compliance is leading a multi-unit partnership to develop a comprehensive Conflict of Interest (COI) and Conflict of Commitment program.

Why This Matters

As an Ohio public university, our faculty and staff are state employees who are subject to the Ohio Ethics Law and other professional standards designed to prevent conflicts of interest and protect the public from biased decisions. These laws carry civil and criminal penalties for violations and apply to all public officials and employees, regardless of position.

Key provisions include:

  • Conflict of Interest – Employees may not use their positions to secure benefits for themselves, their family members, or their business associates. This includes restrictions on financial or fiduciary interests in contracts involving the university.
  • Public Contracts – Employees may not authorize or influence contracts between the university and themselves, their family members, or business associates, nor may they contract with the university that employs them.
  • Supplemental Compensation – Employees may not receive compensation from anyone other than their public employer for performing their public duties.
  • Financial Disclosure – Certain university officials (trustees, presidents, and other executives) must file financial disclosure statements with the Ohio Ethics Commission to ensure transparency and accountability.
  • Gifts – Employees may not accept gifts, travel, meals, or other things of value from those doing or seeking to do business with the university.

Building a robust COI/Commitment program grounded in these legal and ethical standards protects »¨¼¾´«Ã½â€™s integrity, ensures fair decision-making, and upholds public trust.

About the Partnership

The COIC Initiative is co-led by Laura Myers, Director of University Compliance, and Kim Littlefield, Associate Vice President for Research Administration. The work is guided by a cross-campus committee including representatives from Finance, the College of Business, Legal Affairs, University Compliance, Research Compliance, the Heritage College of Osteopathic Medicine, Human Resources, and the Office of Audit, Risk, and Compliance. This diverse membership ensures that policies and procedures reflect the real-world responsibilities of faculty, staff, and administrators across the institution.

Project Purpose

The program’s goal is to protect the university’s integrity, reputation, and research objectivity by clearly defining expectations for outside activities and financial interests. It will establish streamlined processes for identifying, disclosing, approving, and managing both personal and institutional conflicts of interest and conflicts of commitment.

Objectives

  • Protect Institutional Integrity – Maintain public trust by addressing conflicts proactively.
  • Support Transparent Decision-Making – Provide clear guidance for leaders and employees.
  • Comply with Regulations – Align with federal, state, and Ohio Ethics Law requirements.
  • Maintain Professional Focus – Balance core duties with meaningful external engagements.
  • Promote Clarity and Transparency – Clarify legal requirements and set expectations for ethical conduct.

Program Components Under Development

  • Policy 49.001 (Under Review) – Defines COI and conflict of commitment, disclosure requirements, and management options.
  • Automated Annual Disclosure Platform – Launching in 2026 to simplify reporting for all employees.
  • Review and Mitigation Process – Standardized system for evaluating disclosures and applying safeguards (recusal, independent review, etc.).
  • Monitoring & Reporting – Periodic audits and escalation mechanisms to designated authorities.

Timeline & Milestones

  • Policy Approval: Fall 2025
  • Procedures Finalized: Spring 2026
  • Disclosure Platform Implementation: Spring 2026
  • Website & Supervisor Resources: Spring 2026
  • Annual Disclosure Campaign Launch: Summer 2026

Get Involved / Learn More

Faculty, staff, and administrators will find resources, policies, and training updates on the University Compliance website as the program rolls out. Questions can be directed to University Compliance (Office of Audit, Risk, and Compliance) at universitycompliance@ohio.edu or to:

  • Laura L. Myers, Director of University Compliance
  • Mary Ann Boyle, Chief Audit Executive