STATEMENT ON CONFLICTS OF INTEREST

The growth of sponsored research, consulting contracts, staff involvement in management of private companies, and similar developments, have in recent years complicated the relationships between the University, Government, and industry. One of the consequences has been to increase the danger of conflicts of interest between the obligations a University staff member may have under a research contract or grant, and the obligations he may assume in other extramural activities.

The following excerpt from a 1964 joint statement of the American Council on Education and the American Association of University Professors, illustrates the kinds of situations which may give rise to conflicts of interest.

It has long been recognized that the only truly effective safeguard against conflicts of interest situations is the integrity of the faculty and staff. A codification of the complex ethical questions involved, even if possible, would be unduly restrictive. At the same time, even the most alert and conscientious person may at times be in doubt concerning the propriety of certain actions or relationships. Whenever such doubt arises, the University expects the individual involved to consult with the Office of the Chancellor, or the Chancellor's designated representative, before making a decision.

Requests for interpretation of this statement should be referred to the Vice President–Governmental Relations¹; legal questions should be referred to the Office of the General Counsel via the Chancellor or the Chancellor's designated representative.

(Extracted from A Joint Statement of The Council of the American Association of University Professors and The American Council on Education.)

CONFLICT SITUATIONS

1. Favoring of outside interests. When a University staff member (administrator, faculty member, professional staff member, or employee) undertaking or engaging in Government-sponsored work has a significant financial interest in or a consulting arrangement with a private business concern, it is important to avoid actual or apparent conflicts of interest between his Government-sponsored university research obligations and his outside interests and other obligations. Situations in or from which conflicts of interest may arise are the:
   1. Undertaking or orientation of the staff member's university research to serve the research or other needs of the private firm without disclosure of such undertaking or orientation to the university and to the sponsoring agency;

   2. Purchase of major equipment, instruments, materials, or other items for university research from the private firm in which the staff member has the interest without disclosure of such interest;

   3. Transmission to the private firm or other use for personal gain of Government-sponsored work products, results, materials, records, or information that are not made generally available. (This would not necessarily preclude appropriate licensing arrangements for inventions, or consulting on the basis of Government-sponsored research results where there is significant additional work by the staff member independent of his Government-sponsored research);

   4. Use for personal gain or other unauthorized use of privileged information acquired in connection with the staff member's Government-sponsored activities. (The term "privileged information" includes, but is not limited to, medical, personnel, or security records of individuals; anticipated material requirements or price actions; possible new sites for Government operations; and knowledge of forthcoming programs or of selection of contractors or subcontractors in advance of official announcements;

   5. Negotiation or influence upon the negotiation of contracts relating to the staff member's government-sponsored research between the university and private organizations with which he has consulting or other significant relationships;

   6. Acceptance of gratuities or special favors from private organizations with which the University does or may conduct business in connection with a Government-sponsored research project, or extension of gratuities or special favors to employees of the sponsoring Government agency, under circumstances which might reasonably be interpreted as an attempt to influence the recipients in the conduct of their duties.