• All UI employees are required to disclose outside professional activities and financial interests that pose an actual or potential conflict of interest via the eCOI online disclosure system. When possible, disclose any potential or actual conflicts of interest in the workplace in advance of initiating an activity or when the employee, in the exercise of reasonable diligence, first becomes aware of the conflict or the potential for conflict.
• If required, complete an Annual Disclosure of Outside Professional Activities and Interests via the eCOI online disclosure system.
• If a Management Plan is developed, adhere to the conditions of the Management Plan and provide updates, as relevant.

• Review initial disclosure and determine policy relevance.
• Offer recommendations for college/division follow‑up.
• Assign a preliminary COI‑W category.
• Forward Disclosure Report and track review timelines.
• Maintain records of category assignment and Management Plans.
• Send notification of annual review requirements.

• Review and affirm assigned COI category.
• Inform Central Office of final category and Management Plan determination.
• Develop Management Plan when required.
• Obtain signatures and distribute filed copies.
• Monitor Management Plan implementation.

• An interest in an outside entity that may compromise, or have the appearance of compromising, an employee’s professional judgment in performing their University duties (e.g., having a financial interest in an outside company to which the employee may be in a position to refer students/staff resulting in personal gain).

• It is unlikely that the employee will influence a business decision pertaining to the interest or activity, but the appearance of influence exists. Management Plan is needed.
• In the current disclosed scenario, no conflict of interest exists, but it is possible in a changed scenario in the future (e.g., a member of one’s immediate family is enrolled in an academic department, but not currently assigned to a family member’s course at this time). Management Plan is not required at this time, but caution should be exercised.

• The disclosed Outside Professional Activity is considered part of the employee’s position responsibilities (e.g., “academic activities” for faculty).
• The disclosed interest/activity will have no opportunity tocompromise or appear to compromise an employee’s professionaljudgment (e.g., teaching, business decision-making).

1. What types of activities is the employee engaging in with the outside entity (e.g., AdvisoryBoard, Paid Authorship, Editing, Consultant, Company Founder, Expert Witness, Trainer)?
2. Is the professional expertise used in this outside consulting related to the professionalexpertise involved in the employee’s UI position (e.g., technical skills, specialized knowledge,credential/license, teaching)?
3. What type of entity is it (e.g., for-profit, not for profit, public/government, other)?
4. Does the activity interfere/have the appearance of interfering with the performance of theemployee’s assigned duties due to the relationship with the entity (e.g., employee prescribesproducts distributed by company, uses products/services in professional role, evaluates entity’sproducts, participates in purchasing/business decisions, involves UI students or supervisees)?If involves UI students or supervisees, see “E.” and “F." below.
5. Is the employee a full-time faculty member or administrator with a faculty appointment? Ifyes, see “I.” below and also the UI Conflicts of Commitment policy:http://provost.uiowa.edu/conflict-commitment.
6. Is the employee using some type of allowable leave to conduct these outside professionalactivities?

1. If the employee is responsible for business decision-making related to this entity, the employee must be removed from the decision-making process. When the decision involves responding to a competitive bid process, please refer to the UI Purchasing Conflict of Interest policy for requirements.
2. Clarify the extent of any external time and effort commitments and how the employee will assure that his/her university responsibilities are met. If faculty or administrators with faculty appointments, please see the Conflict of Commitment policy for additional guidelines.
3. Ensure that the employee understands that any consulting agreement he/she enters into with a company or outside entity must not conflict with his/her obligations to the University. If a faculty member, provide Information for University of Iowa Faculty on Outside Consulting Activities.
4. Clarify the employee’s responsibilities to ensure that they will not use university resources(e.g., email. phone, website) in connection with these outside activities. Inform employee ofthe following UI policies:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility 

1. Is the outside entity in the same field of expertise or related to the employee’s UI position/responsibilities?
2. What type of position(s) does the employee and/or immediate family member hold in the outside entity (e.g., advisory board, Board of Directors, CEO/Executive, line officer or other position with the ability to influence the entity’s business decisions)?
3. What are the start/end dates of the position?
4. If employment, is the employee expected to generate similar work products for both employers?
5. Could the success of the non-university entity be impacted by the decisions the employee makes in his/her university role?
6. Could the success of the University be directly impacted by the decisions the employee makesin his/her role in the outside entity?

1. Clarify the nature of the employee’s position in the outside entity and any areas in which a conflict may present itself.
2. Clarify the extent of the external time commitment and how the employee will assure that their university responsibilities are met or appropriate leave taken.
3. Clarify that in the course of their work as a UI employee, the employee may not refer anyone to the entity, if the referral will generate a benefit to the employee or a member of their immediate family.
4. Clarify the employee’s responsibilities to ensure that they will not use university resources(e.g., email. phone, website) in connection with these outside activities. Inform employee of the following UI policies:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility 

1. Is the outside entity related to the employee’s University position or in the same field of expertise as their UI position?
2. Does the interest in the outside entity interfere/have the appearance of interfering with the performance of the employee’s assigned duties due to the relationship with the entity (e.g.,employee prescribes products distributed by company, uses products/services in professionalrole, evaluates entity’s products, participates in purchasing/business decisions, uses expertise,involves UI students or supervisees)? If involves UI students or staff, see sections “E.” and “F.” below.
3. In their UI position, does the employee have decision-making authority for any transactions with this outside entity?
4. Does the employee or an immediate family member have the potential to personally benefit from UI interactions with the outside entity?

1. If the employee uses the entity’s goods or services in their UI position responsibilities, full disclosure must be made to the individuals with whom the product is being recommended(e.g., patient, students). If a UI Health Care employee, please refer to UI Health Care Conflict of Interest and Conflict of Commitment Policy Regarding Interactions with Industry for management plan.
2. If employee is responsible for promoting or providing information about the entity’s goods or services to the university community, full disclosure of their financial interest or that of an immediate family member must be made at time of discussion and recusal from all decisions related to the entity must be ensured.
3. If the employee is responsible for business decision-making related to this entity, the employee must be removed from the decision-making process. When the decision involves responding toa competitive bid process or selling a good or service to a state agency in excess of $2,000 after public notice and bid, please refer to the UI Purchasing Conflict of Interest policy for requirements. Further, this relationship should be noted on the UI Vendor Application.

1. What type of intellectual property is generating the royalties/licensing (E.g., royalty from academic books, textbooks, patents from inventions)?
2. Is the royalty paid by a scholarly journal or academic press?
3. Does the employee have the authority to make decisions that would directly benefit him/herself or an immediate family member in the form of royalties/licensing fees (e.g., assigning textbooks from which royalties are earned, using software or other product in one’s UI position)?

1. Ensure that the UI employee is aware of the University of Iowa Intellectual Property Policy (PM V-30). If royalties are received from a book or materials recommended or required in an academic course, faculty members should not profit personally and must abide by the “Royalties from Course Materials” policy *PM 17.17(3).
2. If the employee is responsible for business decision-making related to the copyrighted or patented product, the employee must be removed from the decision-making process. When the decision involves a competitive bid process, please refer to the UI Purchasing Conflict of Interest policy for requirements.

1. What is the relationship between the student and the disclosing employee?
2. Is the student a UI employee (e.g., work study, graduate assistant)? If yes, is the disclosing employee in the supervisory line of authority for the student employee?
3. Is the student enrolled in a course being taught by the employee and/or is the student's academic work being supervised by the assigning employee?
4. Will involvement in the outside activity benefit the student’s academic career (e.g., working in a company related to her/his research interests) or is it unrelated and primarily a monetary arrangement (e.g., babysitting, gardening)?
5. Is the involvement in the outside activity an on-going matter or a brief, one-time event?

The following are guidelines for addressing actual or potential conflicts of interest when students and employees have dual relationships (e.g., outside activities, employment) 

1. In cases where the student is also a UI employee (e.g., research assistant, graduate assistant, work study) and supervised by the faculty member, the Conflict of Interest in Employment (Nepotism) policy applies. Correspondence to the student should identify an administrator who has the authority to serve as a “safe harbor” for the student to report academic concerns that may arise from this dual relationship. See the Section Templates and Resources for sample “safe harbor” language.
2. In cases where the outside interest is substantially related to the employee’s research/scholarly activities and the employee is currently instructing, evaluating, or supervising, directly or indirectly, the student’s academic work or participation in a University program is enrolled in a course being taught by the employee, then the Management Plan must ensure:
   1. Instructional Context: Management of the instructional context involves a qualified, neutral third party to end the evaluative, supervisory and, where possible, instructional functions causing the conflict. If this is not possible, the outside relationship is prohibited during the duration of the course.
   2. Thesis Advising: If the faculty member is the chair or a member of the student’s thesis committee, all members of the committee should be informed of the outside relationship and informed that while the UI does not prohibit these types of dual relationships, that the committee structure is designed to provide balance and assure quality. The student should be notified that the full committee is aware of the situation and be provided with the name of a “safe harbor” in the case that the student believes her/his academic career is being negatively impacted by the outside relationship. See Resources for sample “safe harbor” language.
   3. Program Participation: In any situation in which the disclosing employee has decision making authority related to her/his University position (e.g., program acceptance, awards), the employee should disclose her/his dual relationship with the student and a neutral third party should review all University-related decisions the employee makes about the student.
3. In cases where the outside activity is unrelated to the employee’s university research and professional activities and when a student is enrolled in a course being taught by the employee or the student's academic work is being supervised by the employee, then the plan should involve the provisions above depending on the nature and duration of the outside relationship (e.g., if a one-time, brief activity, then an on-going Management Plan may not be needed). Some colleges may implement stricter guidelines related to student involvement in UI employees’ outside activities/interests, including different provisions for undergraduate and graduate students.
4. All Management Plans should communicate the employee’s role in ensuring the integrity of the employee-student University relationship and establishing clear boundaries between the University-related relationship and the relationship developed via the outside activity. Plan should clarify the employee’s responsibilities per the following University policies, including that he/she will not use University Resources (e.g., email. phone, website) in connection with the outside activity:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility 

1. What is the relationship between the disclosing employee and the other employee – within the University and within the Outside Activity?
2. Are the employees connected via their UI positions anywhere within the supervisory line of authority?
3. Is the outside activity related to the UI position responsibilities of the disclosing employee?

1. If the employees are connected via a supervisory line of authority, then refer to the Conflict of Interest in Employment (Nepotism) policy for management.
2. If no supervisory relationship exists, clarify the employee’s responsibilities to ensure that he/she will not use University Resources in connection with these outside activities. Inform employee of the following UI policies:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility 

1. What is the nature of the disclosed consideration?
2. Is it related to the disclosing Employee’s UI position responsibilities?
3. Is it already being managed under a different policy or consideration above?
4. How likely is the situation to pose or appear to pose a conflict, interfere with the employee’s ability to fulfill her/his employment obligations, compromise her/his professional judgment, or result in personal gain for the employee or employee's immediate family?

1. The intervention will be tailored to the type of disclosure, consistent with the level of management described in the other sections in this document.
2. If it involves consulting in an area related to the employee’s UI position, ensure that the employee understands that any consulting agreement he/she enters into with a company or outside entity must not conflict with his/her obligations to the University. If the employee is a faculty member, provide: “Information for University of Iowa Faculty on Outside Consulting Activities.”
3. Clarify the employee’s responsibilities to ensure that he/she will not use University Resources (e.g., email. phone, website) in connection with these outside activities. Inform employee of the following UI policies:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility 

1. Describe the external time and effort commitments, including start and end dates.
2. Does the time away require absence during “business days”?
3. Will the faculty/administrator miss any scheduled/assigned activities?
4. Will the faculty member be taking any type of leave (e.g., unpaid, vacation, if accrued)?
5. Has the faculty member made satisfactory arrangements to cover all university responsibilities during his or her absence?
6. Has the faculty member engaged in “outside professional activities” during the current appointment year in excess of nine business days per academic term (i.e., Fall, Spring, Summer)?
7. Does engaging in the professional activity advance the skills and abilities of the faculty member, with resultant benefit to the employing unit?
8. Will engaging in the activity be detrimental to the unit or university?
9. Is the faculty member in good standing and meeting expected standards of performance?
10. Does the activity interfere or have the appearance of interfering with the faculty member’s assigned duties?

1. If requires absence during business days, the plan should identify how the faculty member will fulfill his/her university responsibilities including scheduled activities (e.g., classes, meetings, office hours), communication with the department, etc.
2. If leave will be used to eliminate the conflict, description of that arrangement.
3. Clarify the employee’s responsibilities to ensure that he/she will not use University Resources (e.g., email. phone, website) in connection with these outside activities. Inform employee of the following UI policies:
   1. Use of University Supplies
   2. Usurpation of University Opportunities
   3. Acceptable Use of Information Technology Resources
   4. Use of University Name
   5. University of Iowa Intellectual Property Policy
   6. Ethics and Responsibilities for University of Iowa Staff
   7. Faculty Professional Ethics and Academic Responsibility