Conflict of Interest
Delegation of Authority
Major Responsibilities That Can Be Delegated:
- Establishing unit policies and procedures that ensure that:
- UC ANR policies regarding conflict of interest and conflict of commitment are followed
- Affected administrative officials are aware of disclosure and disqualification requirements
- Monitoring, preventing, and reducing possible conflict of interest situations
Major Responsibilities That Cannot Be Delegated:
- Commitment to an open, free and objective environment to ensure that UC’s mission is conducted in an atmosphere free of conflicts of interest
- Accountability for the implementation of a system, or systems that effectively manage potential conflict of interest activities
- Committing UC to an appropriate course of action that assures that no personal financial benefit is derived from the business relationship
Selected Requirements, Risks and Mitigation Measures
Outside activities or interests should be closely assessed to assure the integrity and objectivity of all employees in performance of their UC obligations.
UC employees responsible for sponsored projects at UC must disclose personal financial interests related to such projects.
- A process must be in place to assure the systematic review of all principal investigators’ financial disclosures prior to the acceptance of gifts, contracts or grants.
- UC employees who are required to disclose their financial interests and fail to do so may be in violation of UC’s Conflict of Interest (COI) policy as well as federal and/or state laws, and thus subject to disciplinary action.
- If UC determines that a financial interest might reasonably appear to be affected by the sponsored project, UC will take steps to manage, reduce, or eliminate the conflict of interest.
- Each unit is responsible for maintaining a reasonable balance between competing interests and providing a mechanism to help maintain research integrity, protect UC’s interests, and foster an open academic environment.
UC employees should not purchase or lease goods, contract for services, or otherwise participate in or influence UC business decisions that could lead to personal gain or advantage firms in which employees or a near relative have an interest. Exceptions may be approved by the purchasing services manager if they determine that goods or services are not available from any other external or internal source.
UC resources, supplies, equipment, and facilities as well as staff time must not be used for the benefit of an external entity without proper compensation.
Academic appointees and employees should be encouraged to discuss any potential conflict of interest situations with the unit head and/or the Administrative Policies and Business Contracts Director (non-research related issues) or the Contracts and Grants Director (research-related issues).
Resources and Background Information
- UC Office of the President Conflict of Interest (COI) policy
- UC Office of the President Academic Personnel Manual, Section 025, Conflict of Commitment and Outside Activities of Faculty Members
- UC ANR Policy and Procedure Manual Section 403, Conflict of Interest
- UC ANR Policy and Procedure Manual Section 345, Consulting and Other Outside Professional Activities
- UC ANR Website, What is a Conflict of Interest?
- UC ANR Website, Financial Conflict of Interest Compliance
- UC ANR Guidelines to Research Compliance for Principal Investigators
For more information contact the Administrative Policies and Business Contracts Director (non-research related questions) or the Contracts and Grants Director (research-related questions).