Examples of Outside Activities That Require Disclosure and Approval

June 14, 2024

UO employees are not required to disclose all outside activities. The Conflict of Interest, Conflict of Commitment, and Outside Activities Policy, referred to as the COI/COC Policy, outlines which outside activities employees need to disclose and receive approval for.

Learn Activities Employees Must Disclose 

Below are common examples of outside activities employees must disclose, although they are not exhaustive. 

As a reminder, even if outside activities do not require disclosure, 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
  • 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

Note For Those Who Receive Sponsored Awards: Employees who are listed as a principal investigator or as senior/key personnel on sponsored research also need to disclose activities under the Financial Conflict of Interest in Research Policy.

Example: Courtesy Appointments, Research and Development

A research associate holds a courtesy appointment at another university to conduct research that will likely lead to a new process for removing metals from water, helping create clean water in countries that have limited access.

Why This Requires Disclosure: The courtesy appointment involves research and development that could lead to technological innovations and closely aligns with the researcher's UO job duties. Therefore, the researcher should disclose the courtesy appointment and receive approval under the COI/COC Policy.

Example: Independent Consulting, Research and Development

A professor independently consults for a company to develop math curriculum supports for elementary students with limited English proficiency. 

Why This Requires Disclosure: Although not in the hard sciences, the consulting still involves research and development and aligns with the professor's UO job duties. Therefore, the professor should disclose the consulting and receive approval under the COI/COC Policy.

Example: Hiring Students

An associate professor would like to hire a student she currently teaches to assist with a conference she is helping to organize for a professional association. The professor’s work with the professional association is part of her 20% service.

Why This Requires Disclosure: The professor’s work with the professional association would be exempt under the COI/COC Policy since it is part of her service activities and thus not an outside activity.

However, employment of UO students who the employee currently teaches, directly supervises, or formally advises or employment of other UO employees the employee supervises in the execution of an outside activity requires disclosure and approval. 

Example: Conflict of Commitment, Nonprofits, Managing Daily Operations, Use of Public Resources

A research assistant is helping launch a nonprofit with colleagues from other institutions, frequently working on nonprofit formation documents, responding to emails about the nonprofit, and drafting content for a new website.

Why This Requires Disclosure: This level of involvement qualifies as managing or significantly participating in an entity related to his UO duties, requiring disclosure and approval under the COI/COC Policy.

The activity may also present a conflict of commitment if it interferes with UO work. The nonprofit status or lack of compensation does not exempt it from a conflict of commitment determination.

The research assistant may also be using a UO laptop for the outside activity, and use of public resources in an outside activity is prohibited. 

Example: Equity Ownership, Spinout Company

An associate professor and a postdoctoral scholar working in his lab have identified a novel drug delivery system. After working with Industry, Innovation, and Translation, they cannot identify an existing company who might be a good fit to license the technology. They decide to launch their own company to bring the technology to market.

Why This Requires Disclosure: Equity ownership in a company related to their UO roles requires disclosure and approval under the COI/COC Policy.

Additional consideration must be made to ensure that public resources, such as lab space, laptops, or the time of graduate students working in the UO lab, are not used to benefit the spin-out company.

Clear boundaries must also be made to protect the UO’s intellectual property and determine ownership of future developments.

Still Have Questions?

If you are unsure whether your outside activity requires disclosure and approval under the COI/COC Policy, please email us for a consultation.

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