Disclosing a conflict of interest
A conflict of interest, whether real, potential or perceived, must be disclosed.
Before engaging in activities, services or situations involving a conflict of interest, it is essential to disclose them. These conflicts must be assessed and managed according to relevant university policies, guidelines and procedures.
Once assessed, an appropriate course of action will be implemented to manage the situation, either by avoiding it entirely or by moving forward once measures are in place to manage the conflict.
There can be serious consequences for failing to disclose a real, potential or perceived conflict of interest.
How to disclose a conflict of interest
Disclose to your immediate supervisor.
If you become aware of a real, potential, or perceived conflict of interest or have doubts about a particular situation, you must promptly disclose your concerns to your immediate supervisor.
If your supervisor concludes that this is indeed a conflict of interest situation, they will determine the appropriate course of action to either avoid or monitor the conflict of interest.
If the conflict of interest pertains to you:
- You must agree to the course of action in writing.
- A copy of the agreed-upon course of action will be placed in your personnel file, and copies will be sent to the Secretary-General and the relevant Vice-President.
In the event that you do not have an immediate supervisor, refer to the section “Mechanism for Reporting Conflicts of Interest” in the Policy on Conflict of Interest (BD-4). If you are not an employee, contact the Associate Secretary-General, the Secretary-General, or the Chair of the Governance and Ethics Committee.
Note: If an employee discloses a conflict of interest related to another staff member but is not directly involved in the conflict of interest, they will not be asked to agree to the course of action and nothing will be added to their personnel file.
Disclose to the Reporting Officer.
If the conflict of interest, whether real, potential or perceived, relates to research, complete the Disclosure Report Form.
Submit the form to the Associate Dean responsible for research in your Faculty or School or to the designated Reporting Officer specified in Appendix B of the Policy on Conflict of Interest in Research (VPRGS-5).
The Reporting Officer will determine the appropriate course of action to either avoid or monitor the conflict of interest.
If the conflict of interest pertains to you:
- You must agree to the course of action in writing.
- A copy of the agreed-upon course of action will be placed in your personnel file, and a copy will be sent to the Vice-President of Research and Graduate Studies. If the matter involves a faculty member, copies will also be sent to the Department Chair and Faculty Dean.
Note: If an employee discloses a conflict of interest related to another staff member but is not directly involved in the conflict of interest, they will not be asked to agree to the course of action and nothing will be added to their personnel file.
Disclose to the appropriate authority.
Concordia’s Consensual Romantic or Sexual Relationships Guidelines strongly discourage instructors, including but not limited to, faculty members, faculty administrators, laboratory instructors, principal investigators, TAs, research assistants, staff, and coaches, from starting or continuing consensual romantic or sexual relationships with students.
If, despite this guidance, a relationship of this nature exists or has existed in the past between a student and an instructor, and the instructor is, or may become, responsible for teaching, advising, supervising or allocating resources to the student, or is in a position of authority over them, the relationship must be immediately disclosed to the appropriate authority. Depending on the circumstances, this may be the relevant Dean or Vice-President, University Librarian or Executive Director of the Centre for Continuing Education.
Assessing a conflict of interest
If you are unsure whether your situation is a conflict of interest, talk to your immediate supervisor. In the event that you do not have an immediate supervisor, refer to the section “Mechanism for Reporting Conflicts of Interest” in the Policy on Conflict of Interest (BD-4). If you are not an employee, contact the Associate Secretary-General, the Secretary-General, or the Chair of the Governance and Ethics Committee.
If you and your supervisor need clarification, seek guidance from the Secretary-General, who serves as a resource and can provide information on the application of the applicable policies.
When in doubt, it is strongly recommended that you disclose a potential conflict of interest.
Consequences of not disclosing a conflict of interest
Failure to disclose a real, potential or perceived conflict of interest or failure to comply with university policies may result in serious consequences, including, where applicable, disciplinary action.
Not disclosing a conflict of interest can lead to reputational harm and potential legal ramifications.
In research-related conflicts of interest, not taking proper precautions can lead to loss of funding, reputational harm, invalidation of research findings, allegations of research misconduct, and, in certain cases, degree revocation.