Conflicts of Interest
Conflicts of Interest, Conflicts of Commitment and Outside Activities Policy
Colleges, schools and units manage the Conflicts of Interest, Conflicts of Commitment and Outside Activities Policy. The policy requires prior approval for compensated outside activities as well as disclosures of conflicts of interest to supervisors within the college, school or unit. In the coming months, the new Conflicts of Interest Office in the Office of Research will take ownership of this policy to assist colleges, schools and units with implementation and oversight.
Conflicts of Interest
UGA employees are required to make every reasonable effort to avoid actual or apparent conflicts of interest. Employees have an ongoing responsibility to report and fully disclose any personal, professional or financial interest, relationship, or activity that has the potential to create an actual or apparent conflict with the employee’s UGA duties. Employees make conflict of interest disclosures to their supervisors via the Conflicts of Interest Disclosure Form.
Conflicts of Commitment
UGA employees are forbidden to engage in any occupation, pursuit or endeavor that will interfere with the regular and punctual discharge of that employee’s official duties.
Each UGA employee with a work commitment of 30 or more hours per week (.75 or more FTE) must obtain written approval prior to engaging in compensated outside activities that relate to the employee’s expertise or responsibilities as a UGA employee. Such activities include consulting, teaching, speaking and participating in business, professional or service enterprises.
Certain staff are pre-approved to perform compensated outside activities if all six of the following conditions are met:
- the employee’s UGA job has no supervisory responsibilities;
- the compensated outside activity is not for a current or prospective UGA vendor the employee interacts with, supervises or is involved in the selection or evaluation of;
- the compensated outside activity occurs outside the employee’s UGA work hours;
- no UGA resources are utilized in the performance of the compensated outside activity;
- the employee submits a Staff Notification Form for Pre-Approved Compensated Outside Activities in advance to the employee’s department head or director (with the notification to be re-submitted annually): and
- the compensated outside activity complies with any unit-specific restrictions imposed by the employee’s unit, as approved in writing by Human Resources.
All faculty, and any staff who do not meet the conditions for pre-approval, must submit the Compensated Outside Activities Approval Form.
“Approvers” of outside activity requests should be mindful of any YES answers on the form to questions 7a-f and forward the request to firstname.lastname@example.org before approving of the activity. The Office of Research will review these activities with a sponsored research, intellectual property or startup nexus. The review includes guidance on approval, potential restrictions or related conflict of interest management. Ultimate approval or imposition of restrictions or a management plan lies with colleges, schools and units.
Special Considerations for Outside Activities with Foreign Entities
The University community is strongly encouraged to review this presentation from the U.S. Office of Science and Technology Policy. In particular, pay close attention to the five university case studies and the examples of problematic talent recruitment program contract terms illustrated in slides 9-29. While this presentation emphasizes the risks associated with international engagement, particularly with China, the principles regarding disclosure and management of potential conflicts apply broadly to all countries, as well as to domestic engagement outside the university.
Director- Conflicts of Interest Review & Management
Gene Pope, Office of Research Integrity and Safety, email@example.com, 706-542-3821
Current Policy Owner
Faculty Affairs, Human Resources, Office of Legal Affairs
Current Policy Contacts
Staff Policy Contact: Sige Burden, 706-542-9231
Faculty Policy Contact: Elizabeth Weeks, 706-542-9389