University of Minnesota  Appendix

Conflicts of Interest Categories

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The following list of conflict of interest categories is representative of several different types of conflict of interest situations that may occur. The University has the authority to require additional review and oversight of any conflict of interest matter.

The following categories typically require a conflict management plan. For those activities which reflect a higher level of risk, the conflict management plan will have more restrictive mechanisms to manage, reduce, or eliminate the conflict.

COI Category Description
  1. Receipt of or an Entitlement to Receive Royalties Relating to Research Activities
  1. An individual participating in research on a technology, process, or product developed in whole or in part by that individual in which the individual or a family member 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.
  2. An individual assigning students, postdoctoral fellows, or other trainees to research projects in which the individual or a family member 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.
  1. Business or Significant Financial interests Related to Instructional Activities
An individual assigning students or other trainees to instructional projects, for example, design projects, in which the individual or a family member has a business or significant financial interest.
  1. Business or Significant Financial Interests Related to Research, Teaching and Outreach Activities
  1. An individual participating in clinical trials or evaluation or development of a technology, process, or product owned or controlled by a business in which the individual or a family member has a business or significant financial interest.
  2. An individual assigning students, postdoctoral fellows, or other trainees to projects supported by a business (through sponsored research or a contribution to an academic department) in which the individual or a family member has a business or significant financial interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies.
  3. An individual receiving University-supervised sponsored research support or contributions (whether in dollars or in kind) for research from a business in which the individual or a family member has a business or significant financial interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies.
  4. An individual receiving research support (sponsored research or a contribution) from a business in which the individual or a family member serves on the board of directors or advisory board.
  5. An individual or family member holding an executive position in a business engaged in commercial or research activities directly related to the individual’s University responsibilities.
  6. An individual teaching students, postdoctoral fellows, residents, or other University employees about the products or processes developed, marketed, or sold by a business in which the individual or a family member has a business or significant financial interest.
  1. Business or Significant Financial interests Related to Administrative Responsibilities
  1. An individual 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 individual or a family member has a business or significant financial interest.
  2. An individual taking administrative action on behalf of the University with respect to any supported research activity (sponsored research or a contribution) in which the individual or a family member has a business or significant financial interest in the sponsor or donor.
  1. Professional Referrals
With the exclusion of consulting activities that conform to the consulting policy, individuals while acting in the context of their University duties making professional referrals to a business in which they or a family member has a business or financial interest of which they are 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 individual fully discloses relevant business or financial interests to prospective clients.
  1. Purchasing
An individual in direct contact with suppliers or potential suppliers to the university, or who may directly or indirectly influence a purchasing decision or contract by establishing specification, testing purchased products, evaluating contracted services, or otherwise has official involvement in the purchasing or contracting process involving a business in which the individual or a family member has a business or significant financial interest.
  1. Clinical Care
An individual who provides clinical care and who also has a business interest or a significant financial interest in a business which manufactures or distributes pharmaceuticals, medical devices, or other health care products, and the individual prescribes a branded product of that business.