The UO has two conflict of interest policies.
Employees and sponsored researchers submit conflict-of-interest disclosures under both policies in the Research Administration Portal (RAP). Sponsored researchers should review both policies before submitting a disclosure.
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Conflict of Interest, Conflict of Commitment, and Outside Activities Policy
The Conflict of Interest, Conflict of Commitment, and Outside Activities Policy (COI/COC Policy) helps UO employees meet Oregon State ethics laws while engaging in activities outside the UO.
All UO Employees Must:
- Disclose certain outside activities for themselves and their relatives related to their institutional responsibilities before beginning the activity, even if that activity occurs during a sabbatical or other approved leave.
All UO Employees Are Prohibited From:
- Making private, commercial use without permission of UO supplies, facilities, equipment, employees, records, intellectual property, or any other UO resources
- Using non-public information accessed as a UO employee to obtain a private financial benefit
- Engaging in activities that substantially interfere with their duties to the UO (See conflicts of commitment.)
- Making decisions in their UO capacity that could have a financial impact on them personally, their relatives, or a business with which either is associated
Disclosure and Approval Are Required When an Employee:
- Holds equity ownership in an entity related to the employee's UO duties or field of expertise.
- This includes consulting entities, but does not include consulting as an individual or a sole proprietor. In other words, if an employee owns a consulting company, they would need to disclose that activity.
- Works in exchange for equity in an entity related to the employee's UO duties or field of expertise.
- This does not include publicly traded equity unless the employee has a majority ownership in that entity.
- Participates in research and development or creation of technology, inventions, or software that are closely related to the employee's UO job duties or field of expertise
- Managing or significantly participating in daily operations in the day-to-day operations of an entity related to the employee's UO duties or field of expertise.
- Hiring UO students or other UO employees the employee supervises, teaches, or advises for outside activities.
- Can make an action or recommendation in their UO role that would have a financial impact on themselves, their relatives, or any business with which either is associated
Learn More About What to Disclose
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Financial Conflict of Interest in Research Policy
The Financial Conflict of Interest in Research Policy (FCOI Policy) helps UO researchers meet federal financial conflict of interest in research regulations. This policy has specific training and reporting requirements.
In Addition to Meeting UO's COI/COC Policy, All Sponsored Researchers Must:
- Disclose annually Significant Financial Interests for themselves, their spouse, and their dependent children that are related to their institutional responsibilities.
- Update their disclosure within 30 days of acquiring a new Significant Financial Interest or a change in an existing one
- Complete financial conflict of interest in research training every 3 years.
Significant Financial Interests Include:
A Significant Financial Interest includes any of the following held by the investigator, their spouse, or their dependent children that is related to their institutional responsibilities:
- Publicly traded entity: Remuneration that, when aggregated, exceeds $5,000 in the previous 12 months
- Non-publicly traded entity: Remuneration that, when aggregated, exceeds $5,000 in the previous 12 months or any equity interest
- Intellectual property income: Any income received from intellectual property rights and interests unless the UO manages the intellectual property and pays the income
- Sponsored or reimbursed travel: Reimbursed or sponsored travel paid on behalf of the investigator that, when aggregated, exceeds $5,000 from any one entity unless the travel is funded by a local, state, or federal agency; by a U.S. institution of higher education; an academic teaching hospital; or a research institute affiliated with an institution of higher education
- The travel must be related to the investigator's institutional responsibilities.
Remuneration includes salary, equity, stock, stock options or other ownership interest, and any payment for services such as consulting fees, honoraria, and paid authorship.
Learn More About What to Disclose
Additional Resources
General Information