Conflict of Interest Disclosure Information

The first step in the Conflict of Interst process at Mines is for employees who are required to submit a disclosure to receive a notice that their disclosure is due.  Existing employees will get an email that it is time to submit their annual disclsoure.  Newly hired employees will see the Conflict of Interest disclosure as an action item in their WorkDay onboarding.

The exception to this is when new conflicts arise between reporting periods.  If an employee wishes to engage in a new activity that presents a Conflict of Interest, they must submit an updated disclosure within 30 days.   Employees must proactively contact the Compliance office (compliance@mines.edu) to update their disclosure in this scenario.

The second step is for employees to log on to MetricStream and complete the electronic Conflict of Interest disclosure form.  MetricStream is an online system that employees will access using their SSO.  Your Conflict of Interest disclosures will be housed within this system and is not a part of your personnel file.

For most employees, the process will only take a few minutes.  For those who need to enter multiple disclosures on the form, the process will take a bit longer.

For more detailed information and step-by-step guides on how to submit your Disclosure, please visit our Training and Resources page.

The third step is for the Office of Compliance, Policy, and Risk Management to review the disclosure forms.  In this step, we will determine if a conflict exists and whether further steps are necessary.  

For the majority of employees, the process stops here and no further action is required.

The next step, if necessary, is for the Compliance Office to collect more information.  Occasionally, we will need to reach out to an employee to request clarification or gather additional information.  Usually this will entail answering questions, correction typos, and occasionally collecting additional documents.  If the Compliance Office needs anything  from you after you submit your disclosure, we will contact you.

Upon receiving this additional information, the Compliance Office may determine that no conflict exists and the no further action is required.  The Compliance Office may also determine that a conflict does exists and that further steps are necessary. 

If necessary, the next step is for the Conflict of Interest Committee to review the situation.  The Committee is tasked with making recommendations for managing and mitigating Conflicts of Interest.

The Committee will first confirm that a conflict exists and then determine what conditions or restrictions, if any, Mines should impose to manage, reduce, or eliminate the conflict.   

The final step in the Conflict of Interest process is the Management Plan.  With the Conflict of Interest Committee’s recommendation, a plan will be put in place to manage the conflict.  Because each situation is unique, the Management Plan will be tailored to fit individual circumstances.  The employee’s Department Head or supervisor is responsible for monitoring the employee’s compliance with the requirements of the Management Plan.