Policy

Disclosure of Instructor Proprietary Interest

Applies To: Education Solutions Division – All CE/T Instructors, Course Developers, and Instructional Personnel

Effective Date: June 5, 2026

1. Policy Statement

Early Learning Indiana (ELI) requires full and transparent disclosure of any proprietary interest an instructor, course developer, or instructional personnel may have in products, devices, services, or instructional materials referenced, used, promoted, or recommended within Continuing Education and Training (CE/T) learning events.

This policy ensures objectivity, maintains instructional integrity, and protects learners from undue influence or perceived bias.

This policy aligns with Early Learning Indiana’s established Conflict of Interest and Outside Activities requirements outlined in the Employee Handbook.

2. Definition of Proprietary Interest

For purposes of CE/T programming, a proprietary interest includes, but is not limited to:

• Ownership (full or partial) in the company or product
• Financial compensation related to a product or service
• Paid consulting or advisory relationships
• Royalty arrangements
• Commission-based relationships
• Intellectual property rights that may result in financial benefit
• Employment with or contractual relationship to a vendor whose materials are used

A proprietary interest includes both actual conflicts and perceived conflicts that could reasonably influence instructional objectivity.

3. Disclosure Requirements

1. All ELI employees, instructors, instructional designers, subject matter experts, and course facilitators must disclose any proprietary interest prior to:
   • Delivery of a learning event
   • Inclusion of materials in CE/T programming
   • Renewal of teaching engagement
2. Disclosure must be provided in writing to the Director of Educator Solutions prior to course launch.
3. If a proprietary interest arises during the course of employment or instructional engagement, the instructor must disclose the relationship immediately.

4. Review and Determination

1. The Director of Educator Solutions reviews all disclosed proprietary interests to determine:
   • Whether a conflict of interest exists
   • Whether mitigation steps are required
   • Whether the instructor may continue use of the referenced materials
2. If needed, the Chief Learning Officer will participate in the review and determination.
3. Possible mitigation strategies include:
   • Transparent disclosure to learners
   • Use of alternative comparable materials
   • Removal of the material from instruction
   • Reassignment of instructional duties

5. Learner Disclosure

If an instructor maintains a permissible proprietary interest that does not disqualify instructional involvement, the interest shall be disclosed to learners at the beginning of the learning event in a clear and unbiased manner.

Disclosure language must:

• Identify the nature of the proprietary relationship
• Clarify that participation in CE/T programming does not require purchase of any affiliated product or service
• Ensure learners understand that alternative resources may exist

6. Prohibition of Undue Promotion

1. CE/T instructors may not:
   • Require learners to purchase specific proprietary materials unless explicitly approved as essential course materials
   • Promote products or services for personal financial benefit within learning events
   • Use CE/T instructional time for personal marketing
2. Violations of this provision may result in corrective action consistent with Early Learning Indiana’s Conflict of Interest and disciplinary procedures.

7. Documentation and Record Retention

1. All proprietary interest disclosures shall be maintained digitally by the Director of Educator Solutions.
2. Documentation shall be retained in accordance with ELI’s Record Retention and Disposal Policy.
3. Disclosure documentation shall be made available for accreditation and audit review upon request.