Potential Conflict of Interest Activities and External Relationships (ARTICLE 5, Category II: Activites and External Relationships that have the Potential for Conflict of Interest)
Section II – Minimal to Moderate Ordinarily allowable following disclosure and, where necessary, require the implementation of oversight or other management procedures. | Section III – Moderate to High Case-by-case review required and only some of the specific relationships may be approved. Special oversight or management procedures likely required.
Research Activities (a) An employee participating in research on a technology, process, or product developed in whole or in part by that employee in which the employee, an immediate family member, or an associated entity is entitled to receive royalties from an existing agreement with a business under another academic institution's royalty-sharing policies, but has no other business or significant financial interests in the project. (b) An employee assigning students, postdoctoral fellows, or other trainees to research projects in which the employee, an immediate family member, or an associated entity is entitled to receive royalties from an existing agreement with a business under the University's or another academic institution's royalty-sharing policies, but has no other business or significant financial interests in the project. | Research Activities (a) An employee participating in clinical trials or evaluation or development of a technology, process, or product owned or controlled by a business in which the employee, an immediate family member, or an associated entity has a business or significant financial interest. (b) An employee assigning students, postdoctoral fellows, or other trainees to projects supported by a business (through sponsored research or a contribution) in which the employee, an immediate family member, or an associated entity has a business or significant financial interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies. (c) An employee receiving University-supervised sponsored research support or contributions (whether in dollars or in kind) for research from a business in which the employee, an immediate family member, or an associated entity has a business or significant financial interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies.
Instructional Activities An employee assigning students or other trainees to instructional projects, for example, design projects, in which the employee, an immediate family member, or an associated entity has a business or significant financial interest. | Business Interests (a) An employee receiving research support (sponsored research or a contribution) from a business in which the employee or an immediate family member serves on the board of directors or advisory board. (b) An employee or immediate family member holding an executive position in a business engaged in commercial or research activities directly related to the employee's University responsibilities.
| Administrative Responsibilities (a) An employee taking administrative action on behalf of the University with respect to the University or any University-affiliated organization that is beneficial to a business in which the employee, an immediate family member, or an associated entity has a business or significant financial interest. (b) An employee taking administrative action on behalf of the University with respect to any supported research activity (sponsored research or a contribution) in which the employee, an immediate family member, or an associated entity has a business or significant financial interest in the sponsor or donor.
| Professional Referrals With the exclusion of consulting activities that conform to the consulting policy, an employee while acting in the context of the employee's University duties making professional referrals to a business in which the employee, an immediate family member, or an associated entity has a business or significant financial interest of which the employee is aware or reasonably should be aware. Only in special situations should full-time employees be permitted to engage in this type of activity, for example, when the function is not generally available from other sources and the employee fully discloses relevant business or significant financial interest to prospective clients.
Purchasing Goods and Services (ARTICLE 6, Category III: Purchasing Goods and Services)
Except as allowed in article 4, no employee in direct contact with suppliers or potential suppliers to the University, or who has direct or indirect influence over purchasing decisions or contracts, or otherwise has official involvement in the purchasing or contracting process may: Have any financial, business, or personal interest directly or indirectly in contracts or purchases of goods or services used by the University; or Accept, directly or indirectly from a person or business to which a contract or purchase of goods or services has been or may be awarded, any gift as defined in Board of Regents Policy: Gifts Received and Given by Regents and University Officials. No employee may further accept any promise, obligation, or contract for future award.

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