22.4 Responsibilities

22.4.1 All employees

All employees must observe the policies set out at 22.1 and comply with all the rules set out at 22.3;  All University employees must complete and submit a Conflict of Interest Disclosure Form for External Activities annually; and  All University employees with a new conflict must immediately disclose and discuss with a supervisor as well as contacting the Faculty Affairs Office (faculty and academic staff), or the Compliance Section (other employees).


22.4.2 All supervisors

All supervisors must instruct employees regarding the content of this chapter.  All supervisors must monitor employee activities with regard to receipt of gifts/favors from vendors and sponsors, employment of and transactions involving related parties, use of inside information, purchases of goods and services from research sponsors, and employment of and purchases from “related parties ”. 


22.4.3 All Employees campaigning for public office

All employees campaigning for public office must advise his or her supervisor.


22.4.4 Academic Staff and Faculty

Academic Staff and Faculty must make additional disclosures set out at 22.3.3.


22.4.5 The Dean of Faculty Affairs and the COO

The Dean of Faculty Affairs, for faculty and academic staff, and the COO, for all other employees, must establish procedures to assure compliance with annual disclosure and other Conflict of Interest reporting requirements, provide initial review of disclosed situation, and request the Coflict of Interest Review Panel to assess the fact when it finds the situation that might create conflict of interests or commitments.


22.4.6 The COO

The COO must establish and staff a “Conflict of Interest Review Panel” comprised of the General Counsel, the COO, and two faculty members. The COO is responsible for making determination of appropriate actions regarding conflict of interests or commitments, hearing report and recommendation by the panel. In addition, the COO, for University Officers and Senior Level Executives, must establish procedures to assure compliance with annual disclosure and other Conflict of Interest reporting requirements, provide review of disclosed situation, and report to the President and Board of Governors when it deems necessary.


22.4.7 The Conflict of Interest Review Panel

The “Conflict of Interest Review Panel” (the General Counsel , the CCO, and two faculty members appointed by the Dean of Faculty Affairs) in the office of the COO will assess the facts and report their findings and recommendation to the COO for decision.


22.4.8 The General Counsel

In addition to serving on the COO’s “Conflict of Interest Review Panel,” the General Counsel must review research-related agreements and arrangements for impermissible special provisions and other potential conflicts of interest.

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