What Must Be Disclosed Under the COI/COC Policy

The University of Oregon encourages employees to engage in outside activities that comport with the UO mission, including dissemination, translation and application of research, and commercialization of research, scholarship, and creative activity.

According to Oregon statute (ORS 352.232), the UO must authorize employees to receive outside compensation.

The Conflict of Interest, Conflict of Commitment, and Outside Activities Policy (COI/COC Policy) provides a path to authorizing such activities while also complying with applicable state laws. The COI/COC Policy applies to all UO employees, including those on courtesy appointments and visiting faculty.

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 and Approval

The following outside activities require disclosure and approval before the activity can begin, even if that activity occurs during a sabbatical or other approved leave.

  • 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.
  • 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.
  • 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.
  • 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.
  • Employment of UO students who the employee currently teaches, supervises, or advises or other UO employees who they supervise in the execution of outside activities.
  • 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 and Approval

Many outside activities do not give rise to potential or actual conflicts of interest or commitment. Under the COI/COC Policy, outside activities that fall into the categories below do not require disclosure and approval:

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 one example, this can occur when an employee hires a UO student who they also teach in the execution of their outside activity.

For Any Outside Activity, Regardless of Whether Disclosure and Approval Are Required

Regardless of whether an outside activity is exempt from disclosure and approval or not, employees may not:

  • Make private, commercial use without permission of UO supplies, facilities, equipment, employees, records, intellectual property, or any other UO resources​
  • Use intellectual property from the employee’s UO position in the outside activity without a license agreement
  • Use intellectual property from the employee’s outside activity in their UO position without a written agreement
  • Use non-public information accessed as a UO employee to obtain a private financial benefit​
  • Engage in activities that substantially interfere with the employee’s duties to the UO
  • For full-time, faculty, time commitments to outside activities cannot exceed one day in every seven-day week, generally averaged over a quarter. Prorated by FTE.​
  • The one-day-in-seven principle does not apply to UO holidays or approved leave.
  • For nine-month employees, the one-day-in-seven principle does not apply to summer months in which there is no UO FTE or during sabbaticals.​
  • For hourly and part-time employees, outside activities performed outside of that employment are not considered a conflict of commitment​ 

Submitting a Disclosure and Requesting Approval

Disclosures of outside activities are submitted in the management plan process.

Other Considerations

For Non-U.S. Citizens

Non-U.S. citizens may not be able to accept compensation from an entity other than their primary employer / visa sponsor. Please contact International Student and Scholar Services (ISSS) for more information.

Contact ISSS

Outside Activities for Foreign Entities

If the entity for which the employee will be conducting outside activities is not located in the U.S., they may request an export control compliance screening to ensure that the entity does not appear on any restricted entity lists.

Contact Export Controls

Employees Who Are Also Sponsored Researchers

If the employee serves as a principal investigator or senior/key personnel on sponsored research, they must disclose any outside activity even if there is no monetary value to both sponsors and the UO. Information disclosed to the sponsor must match information disclosed to the UO and vice versa. Common overlooked activities include access to lab space at another institution and honorific titles. Also be sure to include the outside activities in any Digital Persistent Identifiers, such as ORCHID. 

To disclose outside activities to sponsors during the proposal stage, list outside activities in a current or pending support document and/or in a biosketch. To disclose outside activities to sponsors after an award has been made, contact your post-award Sponsored Project Administrator. 
 
To disclose outside activities, even if there is no monetary compensation and the activity is not subject to the Financial Conflict of Interest in Research Policy, submit a disclosure profile in the Research Administration Portal (link prompts you to enter your Duck ID).  

How Can I Learn More?

Employees who are unsure if their outside activity requires disclosure and approval can email our office to request a consultation or submit a disclosure so our team can make a formal 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