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Operations Manual The University of Iowa

PART II. COMMUNITY POLICIES
DIVISION I HUMAN RIGHTS, AFFIRMATIVE ACTION, AND EQUAL EMPLOYMENT OPPORTUNITY

(Written to conform to Regents Procedural Guide 3/74; amended 9/93; 10/95; 9/97)

CHAPTER 18: CONFLICTS OF COMMITMENT AND INTEREST

(President 9/95; 2/03; 4/05; 2/06; 1/09; 8/24/12; 10/1/13; 1/14)

Effective October 1, 2013, and January 2014, this policy has been revised. For the most current version without redlining, return to II-18.

Note: This chapter is one of several that address conflicts of interest of various types at The University of Iowa. Others include: II-5 Consensual Relationships Involving Students, which addresses faculty-student relationships that are either prohibited or discouraged due to role conflicts; and III-8 Conflict of Interest in Employment (Nepotism), which addresses role conflicts when there is a direct reporting line between two employees. See also II-18.7 below for a complete list of policies that address or are related to conflicts of interest.

18.1 Introduction
18.2 General Definition
18.3 Principles of Disclosure, Review, and Management
18.4 Conflict of Commitment
18.5 Conflict of Interest in the Workplace
18.6 Conflict of Interest in Research
18.7 Other University of Iowa Policies Related to Conflict of Interest
18.8 Federal Conflict of Interest Regulations

18.1 INTRODUCTION.
(Amended 10/1/13)

The University of Iowa community is committed to the principle of free, open, and objective inquiry in the conduct of its teaching, research, and service missions. Further, The University of Iowa encourages its employees to engage in external activities that promote the University's mission, contribute to their professional fields, enhance their professional skills, and/or enhance the public good. However, the University also expects its employees to fulfill their University obligations first and foremost commensurate with their appointment requirements. To ensure that external activities are conducted in a manner consistent with institutional and public values, the following policy conveys expectations and procedures to ensure that University employees avoid improper conflicts whenever possible, or otherwise disclose activities for review and management.

After consultation with their relevant employees, individual units within the University may adopt more stringent rules, which must be approved by the vice president or Executive Vice President and Provost responsible for that unit. Other University policies that address conflicts of interest not covered by this policy are referenced at the end of this chapter.

It should be noted that the following rules governing outside professional activities do not apply to the intramural practice of medicine, nursing, and dentistry conducted in the Colleges of Medicine, Dentistry, and Nursing by members of those faculties according to the plan approved and regulated by the Board of Regents, State of Iowa, and specific provisions of the Iowa Code.

The University of Iowa and its employees are committed to the principle of free, open, and objective inquiry in the conduct of its teaching, research, and service missions. Accordingly, it is crucial that University activities be conducted in an atmosphere that is free of conflicts of interest compromising this principle. For the purpose of protecting both the integrity and objectivity of its employees in the performance of their University obligations, it is the policy of the University that conflicts of interest should be avoided where possible, or otherwise disclosed and managed. University employees are compensated for the performance of all assigned duties arising from their employment with the University. In addition, however, there are many opportunities to develop relationships with outside entities and engage in other activities that enhance one's professional competency, render valuable service to the community, and benefit the individual and University. Such activities and relationships must be conducted in a manner consistent with institutional and public values. Occasionally, such relationships or activities create a conflict of either commitment or interest that must be disclosed and managed so as to avoid violation of state or federal law and/or basic principles of ethics and fairness. The existence of a conflict is not always clear-cut. University employees are expected to make a reasonable effort to determine whether their relationships and activities create, or appear to create, such conflicts. If there is any uncertainty, employees should consult their departmental executive officer (DEO) or equivalent.

This policy describes: 1) situations that may raise the question of the existence of conflicts of commitment or interest, and 2) disclosure and management mechanisms to ensure that such conflicts are properly reviewed and resolved or managed. It details the University of Iowa policy for conflict of commitment (II-18.4), conflict of interest in the workplace (II-18.5), and conflict of interest in research (II-18.6).

Failure to disclose a conflict and/or comply with required management strategies constitutes a violation of University policy and may violate state and federal law. Official records of disclosure will be deemed confidential personnel information and not available under the State of Iowa open records law.

After consultation with their employees, individual units within the University may adopt more stringent rules, which must be approved by the vice president (or Executive Vice President and Provost) responsible for that unit. Other University policies that address other types of conflicts of interest not covered by this policy are referenced at the end of this chapter.
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18.2 GENERAL DEFINITIONS.
(Amended 2/06; 10/1/13)

A conflict exists whenever personal, professional, commercial, or financial interests or activities outside of the University have the possibility (either in actuality or in appearance) of: 1) interfering with UI employees' ability to fulfill their employment obligations; 2) compromising a faculty or staff member's professional judgment; 3) biasing research or compromising, or giving the appearance of compromising, the sound professional judgment of its investigators; or 4) resulting in personal gain for the employee or employee's immediate family, at the expense of the University and/or the state.

18.3 PRINCIPLES OF CONFLICT DISCLOSURE, REVIEW, AND MANAGEMENT.
(Amended 4/05; 10/1/13)

Disclosure, review, and management are critical to the application of conflicts of interest and commitment policies. Under these policies, few activities that represent, or appear to represent, a conflict are actually prohibited. Rather, these rules require conflicts to be disclosed, reviewed, and managed appropriately. Disclosure may take the form of reporting a potential or actual conflict in advance of beginning an activity, at the time a conflict arises, and/or through an annual report of outside interests and activities. Depending on the type of conflict, review of a disclosure to determine whether a conflict exists may be conducted by an employee's DEO or supervisor, or by a University office or committee. If a conflict is identified, a written management plan is required to ensure that conflicts do not interfere with the integrity of employees' performance of University obligations. The appropriate method of disclosure and management varies with the type of activity as described in the Conflicts of Interest and Commitment Procedures Guidance document.

18.4 CONFLICTS OF COMMITMENT (EFFORT).
(Amended 4/05; 10/1/13; 1/14)

Outside professional activities are a normal expectation of employees at a research university provided they do not create a conflict of commitment. Many of these activities generally do not require a written disclosure because they are expected to enhance and not interfere with University obligations. However, if the activities do create a conflict of commitment, written disclosure is required.

18.5 CONFLICT OF INTEREST IN THE WORKPLACE.
(Amended 10/1/13; 1/14)

Conflict of interest in the workplace involves situations in which faculty, staff, or student employees have significant financial or other personal considerations that may compromise, or have the appearance of compromising, their professional judgment in teaching or otherwise performing their University obligations. (See also II-18.6 Conflict of Interest in Research [below]; and III-8 Conflict of Interest in Employment [Nepotism].)

18.6 CONFLICT OF INTEREST IN RESEARCH.
(Amended 2/06; 1/09; 8/24/12)

18.7 OTHER UNIVERSITY OF IOWA POLICIES RELATED TO CONFLICT OF INTEREST.
(Amended 8/24/12; 2/14)

18.8 FEDERAL CONFLICT OF INTEREST REGULATIONS.
(Amended 8/24/12)


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