Administrative Policy
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Policy Statement
The University strives to ensure that its research, teaching, outreach and other activities are not compromised or perceived as biased by financial and business considerations.
Institutional conflicts of interest may arise when:
- a University official with a business or significant financial interest in a business entity is in a position to take action on behalf of the University that may benefit or be perceived to benefit the business entity;
- the University licenses an invention to a business entity and holds royalty or equity interests in the entity that may be affected by ongoing University research or other University activities;
- a University vendor donates a gift to the University;
- the University holds investments in a business entity that has a financial or business relationship with the University;
- the University enters into a commercial transaction that compromises or appears to compromise the University’s research, teaching, or outreach mission activities, or its institutional reputation; or
- the University has a business or significant financial interest in a business entity whose commercial interests may be affected by human participants research conducted at the University.
Financial Disclosure for University Officials (FDUO)
University officials and other designated individuals must disclose their significant economic interests and affiliations, and those of their immediate family members (spouse, domestic partner, or dependent) upon their appointment and then annually thereafter, and identify how those interests may relate to their institutional responsibilities.
Annual Reviews
The Conflict of Interest (COI) Program will review reports of University royalty earnings, gifts, purchases, and industry sponsored research projects to evaluate whether any institutional conflicts may arise from these interests. The COI Program will refer potential institutional conflicts of interest to the Institutional Conflict Review Panel for review and action.
Mission Related Commercial Transactions
The General Counsel will assess whether there is potential for an institutional conflict of interest prior to entering into substantive discussions or making an oral or written commitment regarding a commercial transaction that has a value greater than $2M, appears to have a significant impact on the University's mission or raises unusual questions of public interest or public policy.
Human Participants Research Involving More than Minimal Risk
When a unit within the University proposes to evaluate an invention in which the University has a financial interest under the terms of a University licensing agreement, and the evaluation is determined by the Institutional Review Board to involve "more than minimal" risk to human participants, the COI Program staff and Executive Panel will gather information for consideration by the full Institutional Conflict Review Panel. In assessing and managing potential institutional conflicts of interest involving human participant research, the Institutional Conflict Review Panel (ICRP) presumes that the research should not be conducted at the University unless there are compelling circumstances that justify proceeding with the research here despite the institutional conflict. (See Administrative Procedure: Reviewing and Managing Institutional Conflicts of Interest: II. Special Situations)
Reason for Policy
To implement Board of Regents Policy: Institutional Conflict of Interest. This policy and procedure establish a process to manage, reduce, or eliminate institutional conflicts of interest. It is critical to the mission and reputation of the University to maintain the public's trust by ensuring that the University’s research, teaching, outreach, and other activities are not compromised or perceived as biased by financial and business considerations. In addition, because of its numerous and complex relationships with public and private entities, the University must be aware of any relationships involving financial gain that may compromise or appear to compromise its integrity.