22.3 Rules

 

All those working for, or on behalf of, the University must conduct their affairs so as to avoid conflicts of commitment and interest, or even the appearance of such conflicts. 

 

22.3.1 Annual Disclosure

To facilitate evaluation of situations that may give rise to conflicts of interest, formal written disclosure of external activities and commitments is required of all employees each year.  All University employees must timely complete and submit an annual “Conflicts of Interest Disclosure Form for External Activities” to the COO.

 

22.3.2 Immediate Disclosure Requirement

If a situation raising questions of conflict of commitment or interest arises after submission of the annual disclosure, those involved must immediately bring the situation to the attention of designated personnel in the Compliance Section (University Officers and executives), the Faculty Affairs Office (faculty and academic staff), or Compliance Section (other employees).

 

22.3.3 Additional Special Disclosures Required of Faculty and Academic Staff

22.3.3.1  Faculty and Academic Staff must foster the open and timely exchange of results of scholarly activities, informing students and colleagues about outside obligations that might influence the free exchange of scholarly information.

22.3.3.2  Faculty and Academic Staff must disclose on a timely basis the creation or discovery of all potentially patentable inventions created or discovered in the course of their University activities or with more than incidental use of University resources. Ownership of such inventions must be assigned to the University regardless of the source of funding. The inventor must share in royalties earned.

22.3.3.3  In addition to disclosure to the Faculty Affairs Office, Faculty and Academic Staff must disclose in writing to their supervisor, or to the principal investigator on their research, whether they (or Related Parties ) have consulting arrangements, significant Financial Interests, or employment in an outside entity which provides funding to the University or is involved in procurement or technology licensing relationships with the University.

22.3.3.4  In any situations in which the objectivity of a faculty member or Academic Staff could reasonably be questioned as subject to a Conflict of Interest, the affected employee must contact the Faculty Affairs Office for review and determination of appropriate actions.

 

22.3.4 Political Activity

University employees may not use the University’s names or marks (Chapter 15), must not imply University endorsement, and may not use any University resources in political activity or in individual campaigns for office or in political literature. Employees campaigning or fundraising for or holding public office must comply with University policies regarding use of University resources (equipment, services, facilities, property, and their or other employees’ paid work time).

22.3.4.1  Campaigning for Public Office.  Discussion with a supervisor is required if the duties of a campaign or the holding of an office would seriously interfere or conflict with the fulfillment of the employee’s University responsibilities, including hours of work. The discussion should focus on (1) the degree to which the individual would be absent from work and/or the activities related to the employee’s candidacy would interfere with the performance of his or their regular duties; (2) whether temporary suspension of some portion of the employee's responsibilities can be reasonably accommodated without imposing a significant resource burden on the employee's division/office or research unit; and (3) how the absence might be most effectively accommodated.

 

22.3.5 Related Parties

22.3.5.1  University employees may not vote, make recommendations, or in any other way participate in the decision of any matter which may directly affect the appointment, reappointment, tenure (for a faculty member), promotion, salary, or other status or interest of related parties and may not supervise related parties.

22.3.5.2  University employees may not conduct University business with vendors owned or operated by a related party .

22.3.5.3  University employees may not conduct University business with an entity in which a significant interest is held or owned by a related party .

22.3.5.4  The University may not lease or purchase real property owned by a University employee or by a member of that employee’s related party .

 

22.3.6 Gratuities and Favors

University employees may not accept gifts, trips, meals, or other similar blandishments and inducements from those doing business, or wishing to do business, with the University at any level and to any degree.  This prohibition affects sponsors of research as well as vendors. 

 

22.3.7 Purchases from Entities in which the University has a Financial Interest

Review by and advance approval from the Vice President for Financial Management is required for procurement of goods and services from entities that sponsor research at the University, that are licensees of University technology, or who are major contributors to University activities. 

 

22.3.8 I.P. Licensing, Master Agreements for Sponsored Research, Research Collaboration with Commercial Entities

Review for conflicts of interest by University General Counsel is required before entering into I.P. licensing agreements, master agreements with commercial sponsors, or any other agreements providing special access to research (advisory panels, collaboration agreements, review by external committees, and similar research-related arrangements).

 

22.3.9 Confidential, Business-Confidential & Closely-held (Inside) Information

It is forbidden to use confidential, business-confidential and closely-held or similar inside information received as an employee of the University for personal purposes.

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