Overview
This guide outlines the process that The Texas A&M University System uses to collect Employee Compliance Disclosures about Nepotism, Consensual Relationships, and External Employment.
Overview
This guide outlines the process that The Texas A&M University System uses to collect Employee Compliance Disclosures about Nepotism, Consensual Relationships, and External Employment.
Key Information
- The Employee Compliance Disclosure process in Workday is used to disclose Nepotism, Consensual Relationships, and External Employment so potential conflicts of interest can be managed, reduced, or removed.
- Not all System members participate in this process, and participating members may require additional disclosures outside of Workday.
- Employees review or add disclosures during onboarding and the annual campaign (starting September 1 each year) and should add or end disclosures anytime through the My Disclosures app when something changes.
- Disclosures that flag a potential conflict go to the HR Partner for review. Depending on the type and outcome, they may also route to the Chief Executive Approver for a final If the HR Partner determines there is a conflict, the employee’s Manager is notified for awareness.
- External Employment requests are reviewed by the Department Head and HR Partner, then require approval by the Chief Executive Approver. Faculty consulting and related external employment in an Employee’s professional discipline is disclosed outside of Workday.
Background Information
The Employee Compliance Disclosure process was designed to comply with The Texas A&M University System Policies and Regulations. Not all System members will participate in this process and those participating may have established additional requirements that need to be met outside of this process.
Employees are required to disclose potential or actual conflicts of interest related to their responsibilities as employees of the A&M System so that those conflicts can be appropriately managed, reduced, or removed in accordance with applicable laws, System policies and regulations, and member rules and procedures.
Note: The Employee Compliance Disclosure process in Workday only covers Nepotism, Consensual Relationships, and External Employment. Participating members may require additional disclosures outside of Workday.
Terminology
Use the linked System Policy or Regulation to see the official policy where each term is found.
| Term | Policy/Regulation | Description |
| Nepotism | Policy 07.05 | Restrictions on employment relationships between Covered Relatives that prevent an employee from supervising a Covered Relative or making decisions that affect that relative’s employment. |
| Consensual Relationship | Regulation 07.05.01 | A consensual amorous, romantic, or sexual relationship involving a system employee that may create an actual or perceived conflict because of a difference in power or authority. Certain consensual relationships are prohibited or may require an exemption or alternative arrangement.
Note: A consensual relationship between an employee and their spouse is addressed in Nepotism. |
| External Employment | Regulation 31.05.02 | Work or services performed outside of an employee’s primary job duties for compensation or other value. External employment may include work for another Texas A&M University System member or an outside employer and is subject to review for potential conflicts of interest or conflicts with the employee’s regular work responsibilities.
Note: Faculty consulting and/or other external employment related to an Employee’s professional discipline, as defined in System Regulation 31.05.01, is disclosed outside of Workday. Contact your local HR Office for more information. |
| Covered Relative | Policy 07.05, | Related to Nepotism Disclosure
A family member who falls within the degrees of relationship covered by the nepotism policy. See Degrees of Relationship Listing found in the Appendix of the the policy for the full list of relationship types. |
| Alternative Arrangement | Regulation 07.05.01, Section 3.2 | Related to Consensual Relationship Disclosure
A plan for addressing a conflict of interest created when an employee has authority or supervision over someone with whom they have a consensual relationship. The arrangement modifies responsibilities such as supervising, evaluating, teaching, grading, advising, mentoring, or making employment-related decisions to appropriately address the conflict. |
| Exemption Request | Regulation 07.05.01, Section 3.1 | Related to Consensual Relationship Disclosure
An option for a disclosed consensual relationship between an employee and an undergraduate student when exceptional circumstances may warrant an exception to the prohibition. The exemption requires final review and approval by the Chief Executive Approver. |
Disclosure Submission and Update Events
Employees may submit or update Employee Compliance Disclosures at different points throughout their employment. The following events provide opportunities to review existing disclosures and add or end disclosures as needed.
| Trigger | When | Employee Action |
| Annual Campaign | September 1 each year | Review current disclosures through the inbox tasks received and add disclosures as needed |
| Onboarding | Hire | Complete the inbox tasks received as part of the onboarding process |
| Ad Hoc Updates | Anytime | Add or end disclosures using the My Disclosures app on the Workday Menu |
Overview of Roles
The roles below take part in the disclosure process. This section summarizes each role’s general responsibilities, while routing and specific expectations for each disclosure type are outlined in the Disclosure Routing and Responsibilities section.
Employee
Employees are responsible for disclosing potential conflicts of interest when prompted through the annual campaign or onboarding process and whenever a new potential conflict arises or an existing disclosure changes.
Manager
The Manager receives a notification when an employee submits a disclosure and the HR Partner has determined that there is a conflict. The notification is provided for awareness only and does not require action.
HR Partner
Receives a review task whenever an employee submits a disclosure flagging a potential conflict. The HR Partner will review the information provided and determine what action to take based on the kind of disclosure.
Chief Executive Approver
Depending on the type of disclosure and the outcome of the HR Partner’s review, the disclosure may route to the Chief Executive Approver for approval. The Chief Executive Approver reviews the information provided by the employee and the HR Partner’s determination and Action Plan before making a final decision.
Compliance Officers
Compliance Officers do not receive tasks but have access to reports from the Compliance Disclosures support dashboard, which they use to monitor disclosure activity and help ensure employees are staying compliant.
Disclosure Routing and Responsibilities
Each disclosure type has its own routing, with different expectations for the roles involved at each step. The sections below outline the routing and responsibilities for each type.
Nepotism
HR Partner
After the employee submits a disclosure, the HR Partner reviews the relationship, selects the applicable option, and fills out the Action Plan column. Use the information below about each HR Review option to help make the determination and document it.
Option 1: This is not a Covered Relative
- When to choose this option: The individual identified in the disclosure does not meet the definition of a Covered Relative, and no other potential conflict of interest is identified.
- Action Plan: Briefly document the information supporting your determination, if needed.
- Next Steps: The business process is complete once this task is submitted and no further action is required.
Option 2: This is a Covered Relative, but neither relative has responsibility for direct or indirect supervision of the other and does not have authority over any term or condition of the other’s employment, including salary or wages
- When to choose this option: The disclosed individual meets the definition of a Covered Relative, but neither relative directly or indirectly supervises the other or has authority over the other’s employment. Review the reporting structure to confirm that it meets the supervisory requirements of System Policy 07.05, Section 2.2.1.
- Action Plan: Describe the relatives’ reporting and supervisory relationship and explain how potential conflicts are avoided. Include any details that will help the Chief Executive Approver complete their review.
- Next Steps: The disclosure routes to the Chief Executive Approver for review.
Option 3: This is a Covered Relative, and this relationship includes authority over any term or condition of the other’s employment, including salary or wages, and therefore could create the appearance of a conflict of interest
- When to choose this option: The disclosed individual meets the definition of a Covered Relative, and either relative has direct or indirect supervision of the other or authority over the other’s employment. This may include the ability to make or influence decisions related to the other relative’s employment, compensation, or discipline.
- Action Plan: Identify the supervisory or employment-related authority that creates the potential conflict, and describe any proposed actions to address it. Include any details that will help the Chief Executive Approver complete their review.
- Next Steps: The disclosure routes to the Chief Executive Approver for review.
Chief Executive Approver
The approval step occurs when the HR Partner determines that the disclosure involves a Covered Relative.
Consensual Relationships
HR Partner
After the employee submits a disclosure, the HR Partner reviews the relationship, selects the applicable option, and fills out the Action Plan column. Use the information below about each HR Review option to help decide and document it.
Option 1: No Action
- When to choose this option: The disclosed relationship does not violate System Regulation 07.05.01 and does not present a conflict that requires an exemption or alternative arrangement.
- Action Plan: Briefly document why no further action is required, if needed.
- Next Steps: No further action is required. The business process is complete once this task is submitted.
Option 2: Exemption Request
- When to choose this option: The disclosed relationship is between a university employee and an undergraduate student at the same institution. This relationship falls under the prohibition in System Regulation 07.05.01, Section 3.1 and requires approval by the Chief Executive Approver to be permitted. Exemptions may be granted only in exceptional circumstances.
- Action Plan: Document the relevant circumstances or other information needed to support review of the exemption.
- Next Steps: The disclosure routes to the Chief Executive Approver for review.
Option 3: Alternative Arrangement
- When to choose this option: The disclosed relationship involves an individual who is under the employee’s authority or supervision. Consider whether the employee has direct or indirect responsibility for the individual’s employment or academic status, including responsibilities related to hiring, supervising, evaluating, teaching, coaching, grading, advising, mentoring, or providing or obtaining benefits.
- Action Plan: Describe the proposed arrangement and how the employee’s authority or supervisory responsibilities involving the other individual will be addressed.
- Next Steps: The disclosure routes to the Chief Executive Approver for review.
Chief Executive Approver
The approval step occurs when the HR Partner determines that the disclosure requires an Exemption Request or Alternative Arrangement.
External Employment
Department Head
After an employee submits an External Employment disclosure, it first routes to the Department Head for review. The Department Head reviews the information for awareness and accuracy and may add or edit the disclosure details as needed. They must submit to move the business process forward.
HR Partner
After the Department Head completes their review of an External Employment Disclosure, it routes to the HR Partner for review. The HR Partner reviews the information for awareness and accuracy and may add or edit the disclosure details as needed. They must submit to move the process forward.
Chief Executive Approver
All External Employment disclosures require approval by the Chief Executive Approver.