Conflicts of Interest
Introduction
The University of Georgia is committed to helping its faculty and staff recognize, disclose and manage conflicts of interest or commitment, and to ensure proper approval for outside activities. The Conflicts of Interest office assesses university-wide COI policies and related procedures; streamlines disclosure, management and approval processes; and engages the university community in outreach and education.
What is a conflict of interest? Such a conflict may arise when an employee has 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. An apparent conflict of interest exists when a reasonable person would conclude from the circumstances that the employee’s ability to protect the public interest, or perform public duties, is compromised by a personal, financial or business interest.
Conflicts of interest can (and often do) naturally arise out of the university research environment. While certain conflicts of interest may not be allowed or manageable (such as conflicts created by vendor relationships), most can be appropriately managed, particularly in the sponsored research setting.
Overview of Policy and Guidance
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.
The Policy on Conflicts of Interest in Sponsored Programs complies with U.S. Department of Health and Human Services (DHHS) regulations for all Public Health Services (PHS) units, the National Science Foundation Conflict of Interest Policy, and the Department of Energy Interim Conflict of Interest Policy. As part of the sponsored project proposal process, all investigators must comply with the policy and disclose any financial interest or outside activity that could constitute a financial conflict of interest.
The Human Research Protection Program (HRPP) is committed to maintaining objectivity in the research enterprise, avoiding even the appearance of impropriety and ultimately protecting human subjects. The HRPP does this through individual conflict of interest disclosure requirements for study team members and via the Institutional Conflicts of Interest in Human Subjects Research Policy.
Innovation Gateway provides specific Startup Conflicts of Interest guidance to employees who engage, or plan to engage, in startup company activity. This guidance helps employees navigate university policy. Additionally, employees must keep in mind the Human Resources Employment of Relatives Policy and the Office of Legal Affairs Guidance on Georgia law prohibiting state employees from transacting business with the state.