University of Georgia Office of Research

Conflicts of Interest: COI 101

UGA is committed to transparency and integrity in the work of all its employees. A conflict of interest, or COI, occurs when an employee’s personal interests or activities could appear to influence their university duties. While some conflicts of interest can be a natural part of the job, the university requires that all employees disclose these situations, so they can be managed properly, and prior approval is required for some outside activities.

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What is a COI?

Conflicts may include outside interests and activities, as well as conflicts of time and other commitments.  When a conflict occurs, a person possesses two conflicting interests or loyalties, which could interfere, or appear to interfere, with the person’s obligations to the university.

What is an outside activity?

An outside activity is a non-university activity including, but not limited to, employment, consulting, and business activities, whether paid or unpaid.

Can UGA employees engage in outside activity?

Yes, most outside activities are permissible. However, there may be disclosure, COI management, and, in some cases, pre-approval requirements.

Can UGA employees have financial interests in businesses and other entities?

Yes, employees may have financial interests in outside entities, including equity, stocks, and/or option rights.  Employees need to disclose these financial interests when the entity is related to their UGA responsibilities or field of professional expertise.

What are UGA’s COI policies?

There are two primary UGA COI policies:

The Policy on Conflicts of Interest in Sponsored Programs applies to all employees who apply for and/or receive support from sponsored project funding. This policy focuses on disclosure and management of Significant Financial Interests of the principal investigator and key personnel and their spouse and dependent children.

The Conflicts of Interest, Conflicts of Commitment, and Outside Activities Policy requires the disclosure of any COIs and requires the approval of certain outside activities. COI disclosures must be submitted to your college, school, or unit at the time the need for disclosure arises, and annually during performance evaluations. Certain outside activities must be disclosed, managed, and approved before an employee may engage in the outside activity.

General rules you need to know

• Get permission for outside work and other activities: Before engaging in work outside of UGA, in most cases, you first must get approval from your supervisor or department head.
• Disclose your interests: You must report any financial interests or outside activities that might look like a conflict or are related to your institutional responsibilities or field of professional expertise.
• Federal compliance: If you are working on a federally funded project, you must follow specific rules about disclosing financial interests to the University and pre and post award disclosure to federal sponsoring agencies.
• Foreign programs: If you are involved in a foreign talent recruitment program, you must disclose that to ensure UGA complies with federal law.

Special situations

Some areas have their own specific rules:

• Research involving human subjects: If your work involves human subjects, there are additional disclosure requirements to ensure participants are protected and the research stays objective. Learn more from UGA’s Human Research Protection Program.
• Starting a company: If you are planning to form a startup company, Innovation Gateway provides specific guidance to help you navigate university rules.
• Family & personal businesses: You must always follow Georgia law and University policy regarding the employment of relatives and regarding business that you, your family, or your or your family’s company might conduct with UGA. Learn more from UGA Human Resources and the Office of Legal Affairs under State Business Transaction Disclosure Reporting.

Who can help?

The Conflicts of Interest Office is here to help you navigate these rules, streamline your disclosures, and answer any questions you have about managing your outside activities.