Office of the President
September 19, 1967
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
PresidentGovernmental Relations1; legal questions should be referred to
the Office of the General Counsel via the Chancellor or the Chancellor's designated
(Extracted from A Joint Statement of The Council of the American Association
of University Professors and The American Council on Education.)
- 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:
- 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
- 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;
- 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);
- 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;
- 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
- 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.
1Currently, all questions should be referred to the Office of the General Counsel.