Conflicts of Interest and Conflicts of Commitment

Â鶹¾«Æ·ÊÓƵ recognizes that outside employment and other professional activities can enhance employee expertise, support professional growth, and further the University's mission. Employees may engage in outside activities and hold financial interests provided they do not interfere with their University responsibilities or the University's mission.

Conflict of Interest
A conflict of interest occurs when a personal, financial, professional, or other private interest may influence, or appear to influence, an employee's professional judgment or University responsibilities. Examples include:

• Receiving personal benefit from decisions made in an official University role.
• Allowing outside interests to affect objectivity or decision-making.
• Using University resources, personnel, or opportunities for personal gain.
• Actions that could adversely affect students, colleagues, or the University.Ìý
• Situations that create an actual, potential, or perceived conflict between personal interests and University obligations.

Conflict of Commitment
A conflict of commitment occurs when outside activities interfere with an employee's ability to fulfill their primary responsibilities to the University.Ìý Examples include:

• Performing an outside activity during assigned University work hours.Ìý
• Compete with University duties for time and attention.
• Reduce an employee's effectiveness in fulfilling University responsibilities.
• Interfere with teaching, research, service, or administrative obligations.

Who Must Report?

The following individuals ("Reporting Employees") must submit an Outside Activity Report:

• Â鶹¾«Æ·ÊÓƵemployees with appointments of 0.50 FTE or greater (excluding OPS employees, student employees, and graduate teaching assistants); and
• Any Â鶹¾«Æ·ÊÓƵemployee engaged in the design, conduct, or reporting of research, regardless of appointment level, full-time status, or part-time status.

OPS employees, student employees, and graduate teaching assistants are generally exempt unless an outside activity creates a potential conflict of interest or commitment associated with their obligations as an Â鶹¾«Æ·ÊÓƵemployee. In this instance, a supervisor may direct an employee to submit an Outside Activity Report.

All Â鶹¾«Æ·ÊÓƵemployees with any level of appointment continue to be bound by theÌý .

What Constitutes an Outside Activity?

An outside activity includes, but is not limited to, any practice, consulting, employment, teaching, research, speaking engagements, or business (including managerial interests or positions or service on boards or commissions), or other activity, regardless of compensation, which is not a part of the employee’s assigned duties and for which the University provides no compensation.

Generally, outside activities do not include political, religious, social, fraternal, recreational, or personal educational activities unless:

• Professional or board services are provided;Ìý
• The activity creates a material conflict of interest or commitment; orÌý
• The activity is performed for compensation other than the reimbursement of expenses.

What Must be Reported?

A separate report must be filed for each outside activity. If several activities are with a single outside entity or organization, these may be included in a single Outside Activity Report. After the annual submission, there is a continuing obligation to complete a new report if the status of the certification changes.

Disclosure and approval must occur prior to the commencement of any new activity or financial interest.

A Reporting Employee must report any financial interests, or financial or managerial interests of spouses and children and managerial interests of other relatives, if any of the following apply:

• There is a contemplated business relationship with the University or its direct-support organizations;
• There is a relationship of such interest with your University responsibilities; or
• You are engaged in the design, conduct, and reporting of research and hold financial interests with a foreign entity.Ìý

If an outside activity or interest begins without the required disclosure and approval, and a conflict of interest or commitment is later identified, the employee may be required to cease or modify the activity or divest the financial interest. Employees engaged in the design, conduct, or reporting of research who fail to report may be subject to additional sanctions.If any information previously disclosed changes before the next reporting date, a new disclosure report must be submitted.Ìý

Outside activity reports for the fiscal year are due on or before September 30 of each year. Employees who commence employment with Â鶹¾«Æ·ÊÓƵafter September 30 must submit their report within 30 days of their start date.Ìý

How are Outside Activity Reports submitted?

Outside Activity Reports are completed in Workday through a single form that allows you to either report outside activities or certify that you have no outside activities to report. Every Reporting Employee is required to complete a report each fiscal year.Ìý