Safely navigating through conflict of interest and related regulations
There are many policies and regulations related to conflicts of interest. This list highlights several policies that are relevant to University faculty and staff who have financial interests and/or professional relationships with outside entities. The list is intended to provide guidance on how to maintain appropriate separation between an employee's private financial interests and their responsibilities as a public employee.
- Personal use of University resources: University employees may not use University time, property, equipment or other resources to benefit a personal financial interest or an outside entity. Examples of University resources include University office and lab space; University-paid time; staff, students, or trainees; laboratory or office equipment; laboratory or office supplies; University facilities; or the University name or logo.
- Contracts in which an employee has a personal financial interest: University employees, their spouses or domestic partners, or their dependent children cannot become contractors or suppliers of goods or services to any NSHE institution, nor can they have a direct or indirect interest in a company that does so, without prior written approval.
- Recusal from decision making: Employees may not participate in any decision-making, negotiation or transactions on behalf of the University that involve a business entity in which the employee, a family member, household member or business associate have a significant financial interest.
- Non-affiliation with the University: When providing services for an outside entity such as consulting, private practice or training, University employees must notify those who engage them that they are not acting in the name of the University and that the University is not party to the contract nor liable for any of the employee’s actions under the external contract or agreement.
- University email and website: University employees may not use their University email address or website for activities related to personal business or for an outside entity. Links to outside businesses are prohibited.
- Using non-public information: Employees must not share non-publicly available information with an outside entity. For example, do not share proprietary information, biological material, or unpublished data without a University-executed written intellectual property agreement, data sharing agreement or materials transfer agreement.
- Providing information about an outside entity: University employees may provide information to the University community about an outside entity, but they must not require or encourage University faculty/staff/students/trainees to engage with the company as customers or use its services.
- Hiring students or other trainees: To protect students’ and trainees' rights as scholars and researchers, University employees should contact the Conflict of Interest Designated Official listed below prior to hiring University students or other trainees under their direction to work for an outside entity in which they have a financial interest.
- Non-compliant contract terms: University employees’ obligations under an agreement with an outside entity must not restrict or hinder their ability to conduct current or future research or teaching assignments with the University, nor limit their ability to publish work generated at or on behalf of the University, nor infringe on their academic freedom. It is important to read each contract and/or agreement carefully before signing.
This is not an exhaustive list of policies and much of the information is paraphrased. For more information, please contact:
Research Compliance Program Manager
Conflicts of Interest Designated Official
(775) 784-6360 or firstname.lastname@example.org