Overview

The University aims to uphold ethical standards, maintain the trust of stakeholders, and ensure that employees act in the best interest of the university. While the integrity of individual staff members is the primary safeguard against conflicts of commitment and conflicts of interest, the university recognizes that even well-meaning individuals may sometimes be unsure about certain actions and relationships. To provide guidance in such situations, the university has developed a set of policies, regulations, and guidelines detailed in the "Compendium Of Conflict Of Interest And Integrity Policies – Guidance," issued by the Office of the General Counsel.

Conflict of Commitment: The University expects employees to prioritize their university responsibilities over outside activities that could interfere with their duties. A conflict of commitment usually involves issues of time allocation. Employees are required to disclose significant outside commitments and activities to ensure they do not conflict with their university obligations.

Conflict of Interest: The University requires employees to disclose any financial interests or relationships that could potentially influence their university duties. These disclosures are reviewed to ensure that any conflicts are managed, reduced, or eliminated to maintain the integrity of decision-making processes and protect the university's interests.

COI disclosure forms:

Form 700 - For high-level officials, managers, and employees involved in procurement or contracting decisions.

Form 700U - For projects from Non-Governmental Sponsors.

Form 800 - For projects from Federal (non-PHS) sponsors or projects involving Human Subjects.

PHS COI - For projects that flow through any of the agencies under the Public Health Service, such as the National Institutes of Health (NIH), the Centers for Disease Control and Prevention (CDC), or the Food and Drug Administration (FDA).

DOE COI - For projects involved in research that is funded by the Department of Energy (DOE).

Reference links under the Useful Links section on the right column of this site for policies and guidance relating to conflicts of commitment and conflicts of interest.

What is a Conflict of Commitment?

The University of California (UC) has policies in place regarding conflict of commitment. This term refers to situations where an employee's outside professional activities interfere with their responsibilities to the university. The goal of these policies is to ensure that UC employees prioritize their university duties and do not allow outside commitments to detract from their performance or create conflicts of interest. Employees are expected to disclose their outside activities and obtain approval if those activities could potentially interfere with their university responsibilities.

A conflict of commitment may arise when an individual's external engagements, such as consulting, public speaking, personal business endeavors, and other activities, clash with their obligations to the university. This type of conflict typically revolves around how time is divided between these external activities and university responsibilities. Conflict of commitment is addressed through UC's policies, which outline expectations for managing external commitments that might interfere with university responsibilities. These policies help ensure that employees fulfill their duties to the university without conflicts arising from outside activities.

What is a Conflict of Interest?

A conflict of interest is a situation in which the conduct of research could be compromised, or appear to be compromised, by a related financial interest on the part of the PI or Co-PIs.  “Financial interest” is defined as any personal benefit of significant monetary value, including, but not limited to: 

• Salary or other payments received for services
• Equity interests, such as stocks, stock options, or other ownership interests
• Intellectual property rights, such as patents, copyrights, and royalties from such rights, other than royalties received through the University
• Appointment to a position as an officer, director, agent, or employee of a business entity 

Rules regarding conflict of interest apply to all investigators (PI and otherwise) on the project as well as to their spouses, domestic partners, and dependent children.  On projects sponsored by private-sector organizations, any financial interest in the sponsor that occurred within 12 months prior to the date of the funding offer or during the project timeframe constitutes a potential conflict of interest.  University policy prohibits academics, staff, managers, or officials from engaging in any activities that create a conflict of interest between official University activities and any personal interest or obligation.  Because conflicts of interest can arise in the course of an individual’s interactions outside the University, the presence of an actual, apparent, or perceived conflict of interest does not automatically constitute wrongdoing. However, any potential conflicts of interest must be disclosed and managed, and the University has a formal procedure for doing so in compliance with federal and state regulations.  It requires that investigators: 

• Disclose their financial interests and the interests of their spouse/domestic partner and dependent children on the appropriate disclosure form(s)
• Provide updates as the amount and nature of financial interest changes during the period of performance of supported research.  This policy is intended to protect investigators, their sponsored research and other educational and professional activities in which they are engaged, and the University.

Please visit Contracts & Grants: Conflict of Interest Compliance website for COI compliance pertaining to research.

Human subjects and conflict of interest

Research involving human subjects poses special concern with regard to conflict of interest. For example, the research may involve drugs, equipment, materials, or methods in which the investigators, their domestic partner, or their dependent children have a financial interest. Such interests may appear to compromise the rights and well-being of the research subjects as well as the integrity of the related research and therefore must be disclosed. For this reason, potential conflicts of interest in research with human subjects are subject to cautious scrutiny. Disclosure of conflicts of interest related to research including human subjects is included in the Institutional Review Board procedures for each campus, accessible online http://ucanr.org/humansubject.

Use of the University or ANR name, image, brand, and logo

Association of the University of California or ANR name, image, brand, or logo with commercial interests may lead to a conflict of interest. For example, in the course of consulting or research, ANR academics may provide professional evaluations of products or services, but care must be taken to avoid identifying the University with the academics’ opinions or conclusions in any public or private reports that may support their own outside financial interests. Academics must also avoid implying an endorsement on the part of the University or ANR.

Conflict of Interest FAQs