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Conflict of Interest Policy
for OVPR, DRDA, OTT
In recognition of the unique access which OVPR, DRDA, and OTT staff have to information, and the special obligations we have to our faculty clients and to the university, in addition to the changing local and national context in which conflict of interest concerns are more salient, the staffs of OVPR, DRDA, and OTT have drafted a policy statement which provides guidance with regard to conflict of interest issues. The actions of OVPR, DRDA, and OTT staff members have been covered all along by commonly recognized professional standards, by the University policy on conflict of interest at Standard Practice Guide 201.65-1 (which requires that we not use official University position or influence to further the personal gain of ourselves, our families, or our associates), and by the State of Michigan conflict of interest statute. The new policy statement, however, provides more explicit guidance.
Conflict of Interest Policy for:
- Office of the Vice President for Research (OVPR)
- Division of Research Development and Administration (DRDA)
- Office of Technology Transfer (OTT)
The staffs of the Office of the Vice President for Research (OVPR), the Division of Research Development and Administration (DRDA), and the Office of Technology Transfer (OTT) have unique access to information about research and technology transfer opportunities at the University. This unique access confers an explicit responsibility on the staff to ensure that all transactions (proposals, awards, licenses, ancillary agreements, advice, and reviews) are handled expeditiously and in a manner consistent with the rules, policies, and procedures of the University and consistent with the staff member's fiduciary duty to the University. Toward this end, members of the staff will not:
- Use their position for personal or financial benefit outside the normal reward structure;
- Advise or intentionally or knowingly influence other employees to act in a manner contrary to the interests of the University or contrary to their employment responsibilities;
- Compete with the University while pursuing personal or financial interest;
- Show favoritism toward sponsors, licensees, or others, including University employees, to gain personal or financial advantage;<
- Use or disclose information or technology that is the property of the University without appropriate prior authorization;
- Participate in negotiations between the University and an outside organization in which the staff member has a significant financial interest or special relationship* except with appropriate disclosure and management;
- Accept gratuities or favors in exchange for use of influence or special treatment.
Actual or potential conflicts of interest arising from the particular circumstances of a staff member must be disclosed to his or her unit director. The staff member is required to comply with measures, as determined by the unit director, to manage the conflict. The grievance procedure at SPG 201.8 is available to staff members.
* It is presumed that a "significant financial interest or special relationship" exists when:
- the aggregate ownership by the staff member, his/her spouse, and dependent children is more than 1% of the equity in a company not listed on a stock exchange or more than $10,000 current market value in a company with listed stock. Holdings through mutual funds or TIAA/CREF need not be considered.
- the staff member, his/her spouse, or any of his/her dependent children is an officer or director in the company or an employee or consultant to the company.
7/5/1995