Amendments approved by the:	University Senate May 14, 1998 Administration - June 1998 Board of Regents - July 10, 1998
Amendments approved by the:	University Senate February 22, 2001 Administration - March 29, 2001 Board of Regents - June 8, 2001

SECTION I. STATEMENT OF PHILOSOPHY.

Subd. 1. Purpose of Policy. The University and its employees are committed to conducting themselves and University activities in accordance with the highest standards of integrity and ethics and in compliance with applicable state and federal laws related to conflict of interest and objectivity in research as listed in section III. It is the purpose of this policy to set forth the principles for identifying the potential for conflicts and the procedures for reviewing and addressing those potential conflicts that occur to assure that they do not improperly affect University research and other activities.

Subd. 2. Professional Interactions Encouraged. The University of Minnesota actively encourages and participates in interaction with both the public and private sectors as an important component of its research, education, and public service activities. The University encourages the recruitment, retention, and recognition of individuals with creative abilities who can contribute to technology transfer and interactions with business and public entities consistent with their primary commitment to the University. Employees involved in such interactions may receive personal financial compensation in accordance with the principles and guidelines provided in this policy. Research activities supported by grants, contracts, or contributions from public and private entities, as well as individuals, provide a valuable source of funds, equipment, and topics for University research. Professional interactions, including consulting arrangements, between employees and public entities and private businesses advance the University's ability to provide a high-quality research and educational experience for students and enhance employment opportunities for students. University licensing of technology, employee's consulting, assisting in new business start-ups, and other forms of technology transfer to both public and private entities are critical to meeting society's needs. The University is committed to fostering the welfare of the state of Minnesota through interaction by the University with other public entities and the private sector.

SECTION II. APPLICATION.

This policy applies to employees when, on behalf of the University, they are:

(1) responsible for or in a position to influence, the design, conduct or reporting of research or other scholarly activity;
(2) teaching or advising; or
(3) performing outreach or other public service activities.

This policy applies only when the specified combinations of activities and financial or business interests occur.
Article 6 also applies to employees in direct contact with suppliers or potential suppliers to the University, or who have direct or indirect influence over purchasing decisions or contracts, or otherwise have official involvement in the purchasing or contracting process.

SECTION III. COMPLIANCE WITH OTHER POLICIES AND LAWS.

Subd. 1. Applicable State and Federal Laws. Employees must comply with all applicable state and federal laws and regulations, including those related to conflict of interest and objectivity in research. These laws include, but are not limited to, Federal Public Health Service regulations 42 CFR, part 50, subpart F; and 45 CFR part 94; National Science Foundation Grant Policy Manual 510, as amended by 60 FR 35820 (1995); and Minnesota State Statute § 15.43.

Subd. 2. Applicable University Policies. This policy complements the provisions of other applicable policies. These include Board of Regents policies, "Patent and Technology Transfer" "Outside Consulting, Service Activities, and Other Work;" and "Grievance Procedure." Other relevant guidelines include the Board of Regents policy, "Faculty Tenure;" and policies and procedures related to purchase of services. This policy is intended to help implement and expand upon these other related requirements.

SECTION IV. DEFINITIONS.

Subd. 1. Associated Entity. "Associated entity" means any trust, organization, or enterprise over which the employee, alone or together with an immediate family member, exercises a controlling interest.

Subd. 2. Business. "Business" means any corporation, partnership, sole proprietorship, firm, franchise, association, organization, holding company, joint stock company, receivership, business or real estate trust, or any other nongovernmental legal entity organized for profit, nonprofit, or charitable purposes.

Subd. 3. Business Interest. "Business interest" means holding any executive position or membership on a board regardless of compensation.

Subd. 4 Department Head. "Department head" means the immediate administrator, typically the department head, department chair, or director.

Subd. 5. Employee. "Employee" means:

(1) any person possessing either a full-time (more than 66 percent time) or part-time appointment at the University; and

(2) employees, students, and other individuals, whether salaried or not salaried, who on behalf of the University are responsible for, or in a position to influence, the design, conduct, or reporting of the research or other scholarly activity.

Subd. 6. Contribution. "Contribution" means a donation of assets to the University or or its foundations. Assets may be in the form of cash, securities, tangible personal property, partnership interests, or pledges for acceptable assets that are assigned to the University. <

Subd. 7. Executive Position. "Executive position" means any position that includes responsibilities for a significant segment of the operation or management of a business.

Subd. 8. Significant Financial Interest. "Significant Financial interest" means anything of monetary value including but not limited to:

(1) an interest in a business consisting of any stock, stock option, or similar ownership interest in such business, but excluding any interest arising solely by reason of investment in such business by a mutual, pension, or other institutional investment fund over which the employee does not exercise control; or

(2) receipt of, or the right or expectation to receive, any income in one or more of the following forms: a consulting fee, honoraria, salary, allowance, forbearance, forgiveness, interest in real or personal property, dividend, royalty derived from the licensing of technology or other processes or products, rent, capital gain, or any other form of compensation.

Subd. 9. Immediate Family. "Immediate family" means the employee's spouse or domestic partner, and dependent children.

Subd. 10. Participate. "Participate" means to be part of the described activity in any capacity, including, but not limited to, serving as the principal investigator, co-investigator, research collaborator, or provider of direct services or patient care. The term does> not apply to individuals who provide primarily technical or advisory support and have no direct access to the data or control over its collection or analysis. The term also does not apply to the study participants, unless they are in a position to influence the study's results or have privileged information as to the outcome.

Subd. 11. Senior Officer. "Senior officer" means the executive vice president and provost, the senior vice president for academic health, or the academic vice chancellor as indicated by context.

Subd. 12. Sponsored Research. "Sponsored research" means research, training, and instructional projects involving funds, materials, or other compensation from outside sources under agreements that contain any of the following: The agreement binds the University or an affiliated institution to a line of scholarly or scientific inquiry specified to a substantial level of detail; a line-item budget is involved; financial reports are required; the award is subject to external audit; unexpended funds must be returned to the sponsor at the conclusion of the project; or the agreement provides for the disposition of either tangible or intangible properties that may result from the activity.

SECTION I. STATEMENT OF PHILOSOPHY.

Successful implementation of this policy assumes a shared responsibility by all employees and the administration of the University. Employees are expected to comply with all the disclosure requirements described below. Once proposed activities have been administratively reviewed with a plan of action completed and approved, University administration has the responsibility to vigorously defend the activity so long as the employee complies with the plan of action, the disclosure requirements, other University policies, and the law.

SECTION II. DISCLOSURE REQUIREMENTS.

Subd. 1. Disclosure of Financial or Business Interests. Any time an employee plans to initiate an activity that may be classified under category II in article 5 of this policy, the employee must disclose relevant financial or business interests before commencing the activity. Disclosure is required when:

(1) an employee and immediate family members, or associated entity have an aggregated equity interest in a business representing ownership of 5 percent or more or a value of $10,000 or more, as determined through reference to public prices or other reasonable measures of fair market value;

(2) an employee and immediate family members, or associated entity are expected to receive an aggregated annual income of all types from a business equal to or exceeding $10,000 over the next 12 months;

(3) an employee and immediate family members, or associated entity have a commitment for future royalties from a business beyond the next 12 months that are expected to equal or exceed $10,000 in aggregated annual income; or

(4) An employee or immediate family member has a business interest.

Subd. 2. Disclosure When Submitting a Proposal for Sponsored Research. An employee must disclose relevant financial or business interests to the department head at the time of application for research support (from internal or external funding sources) or technology transfer, if the proposal falls under the provisions of this policy. Funding for the project will not be accessible to the employee until the disclosure of financial or business interest is reviewed and approval is given, and other appropriate measures have been implemented in accord with this policy.

Subd. 3. Disclosure When Receiving a Contribution. An employee must provide disclosure when a contribution is given from a business in which an employee has a financial or business interest if:

(1) the contribution exceeds a value of $1,000 in a given year; and

(2) the employee knows or reasonably should know that any portion of the contribution will be used to benefit the employeeís teaching, research, outreach, or public service activities.

Subd. 4. Disclosure When Involved in Review or Advisory Activities. An employee must temporarily excuse oneself from any University committee or review process that is considering an activity in which he or she has a financial or business interest.

An employee must disclose to committee chairs or the appropriate administrator any financial or business interest that might compromise the employeeís judgment while serving as a committee member or making administrative decisions. An example is serving in an executive position for any organization that does business with the University or sets policies or rules that affect the Universityís activities.

Subd. 5. Disclosure When Involved With Technology Transfer. An employee involved with transferring technology through patents or licensing to a business in which the employee has a financial or business interest must disclose the financial or business interest to the > vice president for research.

Subd. 6. Annual Disclosure. Employees are required annually to complete and submit to their department heads the disclosure form reporting all financial or business interests related to research activities and consulting activities. Whenever substantial changes occur that the employee believes may alter the financial or business interests previously disclosed, an updated form must be submitted within 30 days.

Subd. 7. Disclosure to External Entities. Employees must disclose relevant financial or business interests to sponsors of research and in reporting by either written or oral communication research results. When submitting a paper for publication, an employee must disclose to the editor any financial or business interest that may be affected by publication. This provision also applies to release of information to news media.

Disclosure of a relevant financial or business interest must also be made by any employee who makes an appearance, either in person or by way of a written communication, before any public body, commission, group, or individual, to present facts or to give an opinion respecting any issue or matter up for consideration, discussion, or action.

Subd. 8. Additional Information. When considering approval of or monitoring category II activities as defined in article 5, the department head, dean, or appropriate senior officer may require the employee to submit additional clarifying information pertinent to the activity under review. This supplemental information will be treated as nonpublic information to the extent allowed by law.

Subd. 9. Waiving Disclosure Requirement. Employees may be granted a waiver of the requirement to file a disclosure to participate in a specific activity if they can document that:

(1) they are not the principal investigator or a co-investigator on the project; and,

(2) regardless of title, they are not responsible for, or in a position to influence, the design, conduct, or reporting of the research or other activity.

A request for a waiver must be submitted to the employee's department head. The administrative review process should follow the procedure described in section III, subdivision 2 of this article. If the request for the waiver is denied, then the employee must either comply with the disclosure requirements or not participate in the proposed activity.

Subd. 10. Research Collaborations. When employees participate in sponsored research involving sub-grantees, contractors, or collaborators outside the University, the University, to the extent required by the sponsor, will take reasonable steps to ensure that investigators working for these outside entities comply with appropriate conflict of interest disclosure and review requirements. These steps may include requiring the investigators to comply with the Universityís policy or obtaining written assurances from the outside entity that it complies with applicable federal regulations or sponsor policies on conflict of interest.

SECTION III. REVIEW OF APPLICATIONS FOR EXTERNAL SUPPORT OR RECEIPT OF CONTRIBUTIONS

Subd. 1. Review Process. The general purpose of reviews is to assist employees and the University in avoiding or controlling risks to integrity and reputation engendered by such relationships, while at the same time protecting and furthering the interests of employees, the University, and society in the activities supported by sponsored research and contributions as described in article 7.

Subd. 2. Category II, Section II. The department head is the responsible administrator for this section. Upon receipt of the disclosure form, the department head will consider the appropriateness of the activity and will determine a course of action that will be reported in writing to the dean to whom the department head reports. The dean will either approve the department head's action or submit the disclosure for review following the category II, section III procedure. In those instances when the dean does not concur, the activity may not proceed until approval is obtained by the category II, section III review procedure. Review and decisions on proposed activities for this section must be completed within 20 working days after the department head receives the written disclosure.

Subd. 3. Category II, Section III. The dean is the responsible administrator for this section. Upon receipt of the disclosure form, the department head will consider the appropriateness of the activity and will recommend a course of action that will be submitted to the dean to whom the department head reports. The dean will refer the proposed activity to the appropriate Conflict Review Committee (CRC & described below) with or without specific recommendation. The CRC will either endorse the dean's recommendation or suggest to the dean a course of action. The dean will then determine the course of action for the proposed activity and submit the decision to the senior officer to whom the dean reports. The senior officer will either concur or return the plan of action to the dean for revision. For those proposed activities that would benefit from an additional perspective, the senior officer will forward a request to the vice president for research to refer the activity to the Public-Private Partnership Committee (PPPC). The advice from the PPPC will be submitted to the dean, who will determine the course of action and submit the decision to the senior officer to whom the dean reports. The senior officer will either concur or return the plan of action to the dean for revision. Review and decisions on proposed activities for this section must be completed within 30 working days after the department head receives the written disclosure except for those activities referred to the PPPC. The proposed activities that are reviewed by the PPPC must be completed within an additional 30 working days.

Subd. 4. Conflict Review Committees (CRCs). Each senior officer will determine whether the review committees should be organized at the collegiate level or by area (multiple colleges) and, in consultation with appropriate deans, will be responsible for appointing review committee members as described in article 7. Employees will have the opportunity to meet with the CRC to discuss the situation and possible actions.

Subd. 5. Appeal/Reconsideration Process. If an employee believes the determined course of action is inappropriate, the employee may appeal or ask for the decision to be reconsidered by the dean. The dean will then refer the appeal to the CRC to have the activity reconsidered. Upon completion of the review, the dean will act on the recommendation.

Subd. 6. Record Retention. Each dean will maintain records of all disclosure statements filed and all actions taken by the institution, on an award-by-award basis, for at least three years beyond the termination of the award or until resolution of any action by the University or governmental agencies involving the records. All records will be maintained in a manner to protect confidentiality but will be accessible to sponsoring agencies as required by federal regulations or sponsor policies.

Subd. 7. Reporting Requirements to Sponsoring Agencies. Prior to the expenditure of sponsored research funds, the University to the extent required by the sponsor will notify it of the existence of any potential conflict of interest and provide assurance that the interest has been managed, reduced, or eliminated. To fulfill this requirement, the dean of the unit in which the potential conflict of interest has been identified will inform the vice president for research of the potential conflict and how it will be managed, reduced, or eliminated. The vice president for research will provide notice and assurance to the sponsor as required.

SECTION IV. REPORTING OF PREVIOUSLY APPROVED RELATIONSHIPS.

Each dean annually will submit a written report to the appropriate senior officer summarizing all requests and actions regarding category II external relationships. In addition, the dean must report on ongoing category II relationships to ensure that management and oversight activities are being carried out as required. These reports will be forwarded by the senior officers to the vice president for research for transmission to the PPPC, which will review activities for consistency and make suggestions for modification of operating principles and procedures. On behalf of the committee, the vice president for research will communicate its recommendations in writing to the senior officers, who in turn will communicate in writing with their deans. The vice president for research also will consult with appropriate faculty governance committees regarding proposed changes in the operating principles and procedures.

SECTION V. ENFORCEMENT.

Subd. 1. Disciplinary Actions. Breaches of this policy include, but are not limited to, failure to file, intentionally filing an incomplete, erroneous, or misleading disclosure form, or failing to provide additional information as required by the approving authority. A violation of this policy may be the basis for discipline of an employee. If sanctions are necessary, they will be imposed in accordance with other applicable Board of Regents and Administrative policies and procedures. The potential sanctions may include, but are not limited to, the following:

(1) letter of admonition;
(2) ineligibility of the employee for grant applications, Institutional Review Board (IRB) approval, or supervision of graduate students;
(3) suspension;
(4) nonrenewal of appointment; or
(5) dismissal.

Subd. 2. Notification of Failure to Comply. If an employee who is involved with sponsored research fails to comply with this policy, then the dean of the unit must promptly inform the vice president for research of the violation and whether it has biased the design, conduct, or report of research. To the extent required by the sponsoring agency, the vice president for research will then notify the agency of the violation and any corrective action taken or to be taken.

SECTION I. IN GENERAL.

Subd. 1. Conflict of Interest. A conflict of interest occurs when an employee compromises professional judgment in carrying out University teaching, research, outreach, or public service activities because of an external relationship that directly or indirectly affects the financial or business interest of the employee, an immediate family member, or an associated entity.

Subd. 2. Disclosure of Potential Conflicts. The potential for conflicts arises because of the nature and scope of activities engaged in by the University and its employees. The University assumes that potential for conflicts will occur regularly in the normal conduct of activities. However, it is essential that the significant potential for conflicts be disclosed and reviewed by the University. After disclosure the University can then make an informed judgment about a particular case and require appropriate oversight, limitations, or prohibitions on the activity in accordance with this policy. Employees may not engage in activities in which an actual conflict of interest occurs.

Subd. 3. Implications of External Relationships. Employees are encouraged to participate in technology transfer activities and interactions with other public entities and with business. Such activities, referred to in this document as external relationships, may have the potential for conflicts of interest. However, no wrongdoing is implied by the existence of external relationships.

SECTION II. SIGNIFICANT COMBINATIONS OF ACTIVITIES AND EXTERNAL RELATIONSHIPS.

Subd. 1. Categories of Relationships. The potential for a conflict of interest arises when certain behaviors on the part of the employee occur and are coupled to the existence of certain external relationships. Some combinations (category I below) are assumed to not represent a conflict of interest. Other combinations represent sufficient potential for conflict of interest (category II below) that they require review and prior approval by the University before the employee can engage in the activity. Category III below addresses an activity combined with an external relationship that is presumed to be a conflict of interest and is therefore not allowed.

Subd. 2. Application of Policy. The following is a representative, though not inclusive, list of activities and external relationships covered by this policy. The categories are general guidelines, and application of appropriate review and oversight will always be in accordance with maintaining the full integrity or reputation of the University and its employees within the context of academic freedom.

Subd. 3. Relationships Not Specified in Policy. Any combination of activity and external relationship not specifically represented in categories I & III that an employee reasonably believes constitutes a potential conflict of interest must be reported in writing to the employee's department head. The department head will determine whether the relationship represents an activity requiring further review.

The following are not considered conflicts of interest and do not require disclosure. They are allowable if they are consistent with other policies of the University.

(a) An employee receiving income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities.

(b) An employee receiving income from a business of less than $10,000 annually for educational materials. If the employee assigns the materials to University of Minesota students, there must be prior written consent of the department head or dean.

(c) An employee receiving income serving as a special reviewer or on a review panel for a public or nonprofit entity.

(d) An employee receiving royalties under the University's royalty-sharing policy but not having any other relationship with the royalty-granting entity as specified in category II.

(e) An employee participating in a private practice plan pursuant to policies adopted by the Board of Regents.

SECTION I. CATEGORIES IN GENERAL.

The following combinations range from those that are considered to have minimal to moderate potential for conflict of interest (section II) to those that have a moderate to high potential for conflict of interest (section III). The activities in section II are ordinarily allowable following disclosure and, where necessary, the implementation of oversight or other management procedures. The activities and external relationships listed in section III require case-by-case review and only some of the specific relationships may be approved. Special oversight or management procedures are likely to be required. Disclosure and approval procedures are described in article 2.

SECTION II. MINIMAL TO MODERATE POTENTIAL FOR CONFLICT.

Subd. 1. Research Activities.

(a) An employee participating in research on a technology, process, or product developed in whole or in part by that employee in which the employee, an immediate family member, or an associated entity is entitled to receive royalties from an existing agreement with a business under another academic institution's royalty-sharing policies, but has no other financial or business interests in the project.

(b) An employee assigning students, postdoctoral fellows, or other trainees to research projects in which the employee, an immediate family member, or an associated entity is entitled to receive royalties from an existing agreement with a business under the University's or another academic institution's royalty-sharing policies, but has no other financial or business interests in the project.

Subd. 2. Instructional Activities. An employee assigning students or other trainees to instructional projects, for example, design projects, in which the employee, an immediate family member, or an associated entity has a financial or business< interest.

SECTION III. MODERATE TO HIGH POTENTIAL FOR CONFLICT.

Subd. 1. Research Activities.

(a) An employee participating in clinical trials or evaluation or development of a technology, process, or product owned or controlled by a business in which the employee, an immediate family member, or an associated entity has a financial or business interest.

(b) An employee assigning students, postdoctoral fellows, or other trainees to projects supported by a business (through sponsored research or a contribution) in which the employee, an immediatefamily member, or an associated entity has a financial or business interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies.

(c) An employee receiving University-supervised sponsored research support or contributions (whether in dollars or in kind) for research from a business in which the employee, an immediatefamily member, or an associated entity has a financial or business interest, other than royalty income or the entitlement to future royalty income under University royalty-sharing policies.

Subd. 2. Business Interests.

(a) An employee receiving research support (sponsored research or a contribution) from a business in which the employee or an immediate family member serves on the board of directors or advisory board.

(b) An employee or immediate family member holding an executive position in a business engaged in commercial or research activities directly related to the employee's University responsibilities.

Subd. 3. Administrative Responsibilities.

(a) An employee taking administrative action on behalf of the University with respect to the University or any University-affiliated organization that is beneficial to a business in which the employee, an immediate family member, or an associated entity has a financial or business interest.

(b) An employee taking administrative action on behalf of the University with respect to any supported research activity (sponsored research or a contribution) in which the employee, an immediate family member, or an associated entity has a financial or business interest in the sponsor or donor.

Subd. 4. Professional Referrals. With the exclusion of consulting activities that conform to the consulting policy, an employee while acting in the context of the employeeís University duties making professional referrals to a business in which the employee, an immediate family member, or an associated entity has a financial or business interest of which the employee is aware or reasonably should be aware. Only in special situations should full-time employees be permitted to engage in this type of activity, for example, when the function is not generally available from other sources and the employee fully discloses relevant financial or business interest to prospective clients.

Except as allowed in article 4, no employee in direct contact with suppliers or potential suppliers to the University, or who has direct or indirect influence over purchasing decisions or contracts, or otherwise has official involvement in the purchasing or contracting process may:

(1) have any financial, business, or personal interest directly or indirectly in contracts or purchases of goods or services used by the University; or

(2) to which a contract or purchase of goods or services has been or may be awarded, any gift as defined in Board of Regents policy "Gifts Received and Given by Regents and University Officials." No employee may further accept any promise, obligation, or contract for future award.

SECTION I. CONFLICT REVIEW COMMITTEES.

Subd. 1. Formation and Membership. Senior officers will form one or more Conflict Review Committees (CRCs) for their areas to review the potential for conflicts of interest respecting sponsored research, funding and contributions. Committees may be organized by area (multiple colleges) or for particular colleges where the number of such cases or their nature justify a separate committee. Three-quarters of the voting membership of each CRC will be faculty members from the area or colleges to be served. The remaining one-quarter of the voting members will include faculty from outside the colleges and representatives from outside the University. Some of the members should be individuals who have participated in approved external relationships. Each CRC will also include nonvoting staff representation from the Office of Research and Technology Transfer. The senior officers will decide on the composition of each CRC and select its members in consultation with the appropriate deans.

Subd. 2. Principal Objective. The principal objective for the review committees and responsible administrators is to help guard employees and the University from engaging in activities where the risk to integrity and reputation as a result of an external relationship outweighs the value of the activity to academic and societal goals. Relevant factors for the review committees and responsible administrators to consider are the size of the financial interest, when the relationship commenced, whether the conditions of the relationship have changed during the past year, the likelihood of actual conflict (will the results of the activity likely be affected by or affect the financial interest), mechanisms to ensure integrity (peer review, other independent research sites, and independent monitors or controls), the importance of the proposed activity, and the availability of alternatives to avoid the conflict or apparent conflict.

Subd. 3. Possible Recommendations. One possible recommendation as a result of the review is approval of the activity as proposed if it is concluded that the potential for conflict is so remote or inconsequential that there is minimal probability for biasing the objectivity of the activity. Other possible recommendations are to require periodic peer review of the activity (oversight) by individuals independent of the employee, outside monitors for the activity, divestiture of the financial or business interest, modification of the plan of work, or assignment of different employees without a financial or business interest to control the activity. To the extent possible and reasonable under the circumstances, and in light of the importance of the activity, the review committees and responsible administrators will work with employees to develop means for the activity to take place while protecting the integrity and the reputation of the employees and the University. In special circumstances, upon receiving advice from the PPPC, the senior officer may approve the activity for a limited period of time due to the potentially great benefit from the activity even though there is a high potential for conflict of interest.

SECTION II. PUBLIC-PRIVATE PARTNERSHIP COMMITTEE.

Subd. 1. Formation and Membership. The vice president for research will form a Public-Private Partnership Committee (PPPC) to advise the University administration on complex ethical issues that cannot be resolved by direct application of existing policies. Although some members of this committee will be drawn from within the University to provide relevant information and guidance, the majority will represent a broad spectrum of constituencies outside the University.

Subd. 2. Responsibilities. The PPPC will provide advice on how to handle proposed activities that require an additional perspective beside that provided by the CRC. The PPPC will also annually perform a retrospective review of all decisions involving category II relationships and provide advice on how policies and procedures might be modified to maintain the integrity of the institution. The vice president for research will serve as the liaison between the PPPC and the senior officers. The vice president for research also will confer with appropriate faculty governance committees regarding proposed changes in the operating principles and procedures.

SECTION I. IN GENERAL.

This policy takes a broader view of the potential for conflict of interest and contains more stringent guidelines than the policy it replaces. As a result, it is expected that certain existing relationships of employees will have to be modified. In order to implement the policy, employees must disclose all existing external financial or business relationships to department heads for review as specified in article 2. This provision also applies to all new employees hired after this policy is adopted. The following section sets forth transitional rules for removing identified conflicts. They apply to activities department heads and deans have determined to be unallowable.

SECTION II. MECHANISMS FOR REMEDIATION.

If a department head or dean decides an existing combination of an activity and external relationship is unallowable, the employee can do any of the following to remove the potential for conflict of interest.

(a) Divestiture of financial or business interests in publicly traded businesses: Within three months following the administrative decision, the employee must divest at least 75 percent of relevant stock holdings; 100 percent of the stock must be divested by the end of the sixth month.

(b) Divestiture of financial or business interests in privately held businesses: The employee will be required to divest from financial or business interest at the earliest reasonable time in the judgment of the department head or dean. The University must be assured that the academic employee will not be obligated to future activities or responsibilities for the business.

(c) Retaining financial or business interests but withdrawing from University activity: In lieu of divestment of a financial or business interest, an employee may retain the interest and instead discontinue the University activity in question. In such circumstances the employee may continue to participate in the research for a period not to exceed six months following notification that the combination of activities and external relationships is not approved. Under such circumstances, the implementation of appropriate monitoring procedures may be warranted during such period.

(d) Resigning or taking a leave from an executive position in business related to an employee's University activity: A full-time employee with an executive position in a business that is deemed unallowable must resign or take a leave of absence from the position within a period determined to be reasonable under the circumstances. In no case will this period exceed six months from the determination that the relationship is not acceptable. In making these arrangements, efforts will be made to minimize the disruption the change might create for the parties involved.