UO employees do not need to disclose all outside activities. The Conflict of Interest, Conflict of Commitment, and Outside Activities Policy, referred to as the COI/COC Policy, specifies which outside activities require disclosure and approval.
Those 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.
Here, we provide examples of common outside activities that require disclosure under the COI/COC Policy. These examples offer concrete instances in which disclosure and approval is required, but they are not the only examples in which disclosure is required.
As a reminder, even activities that are not subject to disclosure and approval under the COI/COC Policy still require that employees follow the general guidelines in Section III of the policy. These guidelines are:
- Employees cannot make private, commercial use without permission of UO supplies, facilities, equipment, employees, records, intellectual property, or any other UO resource.
- Employees cannot use non-public information accessed as a UO employee to obtain a private financial benefit.
- Employees cannot engage in activities that substantially interfere with their UO job duties. Please note that the policy itself specifies criteria for determining whether an outside activity may substantially interfere.
Learn More About Activities That Require Disclosure Under the COI/COC 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: Under the COI/COC Policy, research that becomes part of research and development or that could reasonably lead to technological improvements, inventions, or software must be disclosed and approved using a management plan. In addition, this outside activity is closely aligned with the researcher’s UO job duties, which also requires disclosure and approval.
Example: Independent Consulting, Research and Development
As an independent consultant, a professor consults for a company to develop curricular supports in math for elementary students with limited English proficiency.
Why This Requires Disclosure: Research and development doesn’t happen just in the hard sciences. Under the COI/COC Policy, research that becomes part of research and development or that could reasonably lead to technological improvements, inventions, or software must be disclosed and approved using a management plan. In addition, this outside activity is closely aligned with the professor’s UO job duties, which also necessitates the disclosure and approval.
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 via a management plan.
Example: Conflict of Commitment, Nonprofits, Managing Day-to-Day Operations, Use of Public Resources
A research assistant, in coordination with colleagues from other institutions, is launching a new nonprofit. There is a lot of work to do! He often finds himself reviewing nonprofit formation documents, responding to emails about the nonprofit, or drafting content for a new website in between meetings.
Why This Requires Disclosure: This outside activity would rise to the level of managing or significantly participating in the day-to-day operations of an entity that carries on activity closely related to the employee’s UO job duties and/or within their field of expertise. Under the COI/COC Policy, disclosure and approval via a management plan is required.
In addition, there may be a conflict of commitment if the outside activity is interfering with his UO job duties. This analysis does not change just because he is not receiving payment nor because the outside entity is a nonprofit. 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 an entity that carries on activities closely related to an employee’s job duties and/or within their field of expertise requires disclosure and approval via a management plan. 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 potential revisions or derivative works.
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.