Conflict of Interest, Commitment, and Outside Activities Information

Requests for Approval

A Request for Approval form is submitted for an outside activity that will occur in the future.

Outside activities that require prior approval are:

• All outside employment or other compensated activity
• Any outside activity, regardless of compensation, that reasonably appears to create a conflict of interest or a conflict of commitment; and
• Outside board service as described in Section 29.6.4 of the policy
• Foreign Affiliations - Any substantial relationship between an employee and any program sponsored, funded, directed, or controlled by a foreign government, foreign agency, or foreign institution. In particular, any participation in foreign talent programs or honorary / position titles that may be perceived as employment of a foreign institution.  
  • Note: Some activities may be considered pre-approved. (Please see section 29.6.3 of the policy for more information). Substantial relationships with foreign entities are not considered pre-approved and a request for approval must be submitted.
  • The outside activity portal does not prevent from submitting a request for pre-approved activities. Employees may choose to submit anyway.
• All employees must electronically request and receive prior approval before engaging in an outside activity with annual approval required thereafter (Including ongoing activities).
• The permissible level of time commitment to outside activities cannot exceed an average of 8 hours per week, during the term of an appointment, without approval of the President or designee and a written management plan.

Disclosures

• A disclosure also covers family members
• Any substantial interest in a business entity should be disclosed no later than 30 days after acquiring the interest.

• Executive Officers who are defined as all individuals who report directly to the President (other than administrative support positions), and any employee who exercises broad and significant discretion over key institution functions. 
• Employees involved in procurement activities - an employee who makes decisions or recommendations regarding
  • contract terms or conditions on a contract
  • who is to be awarded a contract
  • preparation of a solicitation for a contract
  • evaluation of a bid or proposal
  • minimum threshold for purchases and contracts over $15,000
• When in doubt in determining whether an activity or interest should be disclosed, the individual should resolve the doubt in favor of disclosure. 

• Disclosures must be made using the Outside Activity Portal and completed and submitted for activity that took place in the previous calendar year.
• When in doubt in determining whether an activity or interest should be disclosed, the individual should resolve the doubt in favor of disclosure.
• The Annual Disclosure and Certification Period occurs annually from January through March, however disclosures can be submitted at any time.

Report No Activity

Executive Officers, employees involved in procurement activities, and employees involved in contract management with nothing to disclose must affirmatively indicate that fact in the electronic database.

If you are a full-time employee who is required to make an annual disclosure and you have nothing to report, please log into the portal ‘Report No Activity.’