What Must Be Disclosed Under the COI-COC Policy

UO employees do not need to disclose all outside activities. The Conflict of Interest, Conflict of Commitment, and Outside Activities Policy specifies which outside activities require disclosure and approval.

Disclosing an outside activity does not necessarily mean a conflict exists, and many conflicts are acceptable. Our staff work with employees, their supervisor, and appropriate leadership to explore options for managing conflicts.

Activities That Require Disclosure

Some types of outside activities frequently give rise to potential or actual conflicts of interest or commitment. For this reason, employees are required to disclose:

  1. Ownership of equity in an entity that carries on activities closely related to the employee's UO job duties or within their 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.
  2. Outside activities performed in exchange for equity in an entity that carries on activities closely related to the employee's UO job duties or within their field of expertise. This does not include publicly traded equity unless the employee has a majority ownership in that entity.
  3. Outside activities that are closely related to the employee's UO job duties or within their field of expertise that involve research and development or that involve the creation of technological improvements, inventions, or software.
  4. Management or significant participation in the day-to-day operations of an entity that carries on activities closely related to the employee's UO job duties or within their field of expertise.
  5. Employment of UO students in an outside activity for whom the employee currently teaches, directly supervises, or formally advises.
  6. Any activity or financial interest of the employee or their relatives or any business with which either is associated that could or would be impacted by the employee acting in their capacity as a UO employee.

Activities That May Not Require Disclosure

Many outside activities do not give rise to potential or actual conflicts of interest or commitment. These types of activities are considered exempt from disclosure under the COI/COC Policy.

Please note that there may be instances in which the outside activity does fall into an exempt category, but still requires disclosure as there is a conflict of interest as defined in the COI/COC Policy. As one example, this can occur when you hire a UO student who you also teach in the outside activity.

If unsure whether to disclose the activity, disclose it! Disclosing the activity places the burden of compliance on the university, and our team will be able to make a determination and help with any next steps.

Even if disclosure is not required, employees should follow general guidelines that prohibit personal commercial use of UO resources or non-public information. The outside activity should be performed outside of work and not substantially interfere with UO employment. If unsure if this exemption applies, please disclose the activity so our staff can help make a determination.

Common exempt outside activities include:

  1. Outside activities that are unrelated to the employee's UO job duties.
  2. Reimbursement for travel, although such activity remains subject to ORS 244.025 regarding gifts and ORS 244.042 regarding honoraria. For employees who receive sponsored awards, reimbursement for travel should be disclosed under the Financial Conflict of Interest in Research Policy.
  3. Appearances, performances, exhibits, or publications.
  4. Consulting as an individual or sole proprietor, although consulting in some circumstances may still require disclosure.
  5. Uncompensated outside activities related to the employee's UO job duties.

How Do I Disclose?

Employees submit disclosures of their outside activities using the Research Administration Portal.

Login to the Research Administration Portal

How Can I Learn More?

Employees who are unsure if their outside activity should be disclosed are encouraged to submit a disclosure so our team can make a determination.

Employees may also enroll in a MyTrack course describing the activities that require disclosure, browse our frequently asked questions page, or contact us directly with questions.

A Note About Relatives and Conflicts of Interest

Employees should disclose in the Research Administration Portal if they have a relative who could be impacted by their work at the UO. These conflicts often arise for UO employees who have the ability to take action or make decisions that could have a financial impact on their relative or on that relative's business.

A relative, according to state law, includes:

  • The spouse, parent, stepparent, child, sibling, stepsibling, son-in-law or daughter-in-law of the employee
  • The parent, stepparent, child, sibling, stepsibling, son-in-law or daughter-in-law of the spouse of the employee
  • Any individual for whom the employee has a legal support obligation
  • Any individual for whom the employee provides benefits arising from the employee’s public employment or from whom the employee receives benefits arising from that individual’s employment