22.8 Definitions

22.8.1 Conflict of Commitment

If the external activities and engagements of employees demand or consume so much of their time, effort, or attention that their ability to satisfy their obligations to the University is adversely affected, a Conflict of Commitment exists.


22.8.2 Financial Interest

Financial Interest is an actual or foreseeable nontrivial financial benefit resulting from a decision.


22.8.3 Gift

For purposes of this chapter, a “gift” is any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, service, training, transportation, lodging, meals, or other item that constitutes a personal benefit to the recipient, which is offered/given by anyone doing business with the University or desiring to do business with the University, including sponsors of research.  A gift to a family member of a University official or a gift to any other individual based on that individual's relationship with a University official, may be considered a “gift” for purposes of this chapter if it is given with the knowledge and acquiescence of the University employee and if the University employee has reason to believe the gift was given because of the recipient's University status.  The word “gift” as used in this Chapter does not include any gift (contribution, donation, bequest) made to the University as described in Chapter 7, Fundraising.


22.8.4 Individual Conflict of Interest

When there is a divergence between an individual's private interests and his or her professional obligations to the University, such that an independent observer might reasonably question whether the individual's professional actions or decisions are determined by considerations of personal gain, financial or otherwise, there is an Individual Conflict of Interest. An individual conflict of interest depends on the situation, and not on the character or actions of the individual.


22.8.5 Institutional Conflicts of Interest

An Institutional Conflict of Interest may occur when the University, any of its University Senior Level Executives,  members of the Board of Governors, or a graduate school, division, or other sub-unit, or an affiliated foundation or organization, has an external relationship with or Financial Interest in an entity that itself has a Financial Interest in University projects, research, or business transactions. University Officers, Senior Level Executives or members of the Boards of Governors may also have conflicts when they serve on the boards of (or otherwise have an official relationship with) organizations that have significant commercial transactions with the University. The existence (or appearance) of such conflicts can lead to actual bias, or suspicion about possible bias, in the review or conduct of research at the University. If they are not evaluated or managed, they may result in choices or actions that are incongruent with the missions, obligations, or the values of the University.


22.8.6 Related Parties

For the purpose of this policy and chapter, “related parties” include, but are not limited to, an employee’s immediate family members (parents, siblings, spouses, children, other relatives within third degree of kinship), persons living in the same the home/residence as the employee, persons with whom the employee has a close personal friendship, and persons with whom the employee has a business partnership or association.


22.8.7 University Officers

University Officers for purposes of this chapter are persons performing in the following capacities:

 Vice CEO, and


22.8.8 Senior Level Executives

University Senior Level Executives are defined in Chapter of the PRP.

Senior Vice President,


Secretary General,

Vice President,

Dean (including Dean of Faculty Affairs and Dean of the Graduate School),

General Counsel, and

Any other person designated by the President/CEO


22.8.9 Academic Staff

Academic Staff for purposes of this chapter are persons performing in the following capacities:

Postdoctoral Scholars,
Research Scientists,
Technical Staff working in a research unit, and
Any other position for academic and/or scientific activities of the University.


22.8.10  Security Export Control

“Security Export Control” refers to the implementation of export control from the perspective of security, in accordance with the international framework, in order to prevent the transfer of weapons or goods/technologies that can be diverted to military use by states that threaten the safety of the international community, terrorists, or others who may engage in activities of concern.

Table of Contents