Annual Policy Notification: Conflicts of Interest, Gift Law, Disclosure of Outside Activities, and Related Policies 

MEMORANDUM TO: 
All University of Iowa Faculty and Staff

FROM:  

Kevin Kregel, Executive Vice President and Provost
Martin Scholtz, Vice President for Research
Brooks Jackson, Vice President of Medical Affairs and Dean of the Roy J. and Lucille A. Carver College of Medicine
Cheryl Reardon, Chief Human Resources Officer and Associate Vice President        

DATE:Sept. 29, 2022

SUBJECT: Annual Policy Notification: Conflicts of Interest, Gift Law, Disclosure of Outside Activities, and Related Policies 


The University of Iowa is committed to the principle of objective, fair, and equitable treatment of all employees. It is crucial that university activities be conducted in an atmosphere that is free of actual or apparent conflicts of interest. For the purpose of protecting both the integrity and objectivity of its employees in the performance of their university obligations, and to create a workplace environment based in equity and fairness, it is the policy of the university that conflicts of interest should be avoided where possible, and otherwise disclosed and managed.   

The existence of a conflict of interest is not always clear-cut. University employees are expected to make a reasonable effort to determine whether their activities create, or appear to create, such conflicts. If there is any uncertainty, employees should consult their departmental executive officer (DEO) or equivalent, or supervisor.   

Please review the information listed below, and bookmark the Annual Policy Notifications page on the University Human Resources website for your reference. Policy notifications such as this one are required by federal law. Additional policies will be highlighted in future communications.  

CONFLICT OF INTEREST IN EMPLOYMENT (NEPOTISM)  

Generally, a conflict of interest in employment can arise when two individuals who have a current or former relationship outside the work setting are in a position where one can make decisions affecting the employment status of the other. This could make it difficult for the individual with the decision-making responsibility to be objective, or it may create the appearance, to a reasonable third-party, that such an individual may not be objective.  

To review the complete policy, please see the UI Operations Manual.    

CONFLICT OF COMMITMENT  

A conflict of commitment involves a situation in which a faculty or staff member engages in an "external activity" (see II-18.4d for definition), which requires time and/or effort such that the activity interferes, or appears to interfere, with fulfillment of the faculty or staff member's obligations to the university.  

To review the complete policy, please see the UI Operations Manual.   

UI HEALTH CARE CONFLICT OF INTEREST POLICY  

The success of University of Iowa Health Care depends on a talented and creative faculty and staff who earn regional, national, and international recognition for their contributions to teaching, research, clinical care, and the advancement of their diverse clinical and scientific specialties. As a result of their expertise and experience, faculty and staff have opportunities to engage in professional activities outside UI Health Care. Participation in these activities may also create real and/or perceived conflicts of interest and conflicts of commitment. UI Health Care must continue to make it possible for faculty and staff to advance teaching, service, and research through collaborations with industry in a manner that avoids real or perceived conflicts of interest or commitment.  

To review the complete policy, please see the UIHC Conflict of Interest Policy.  

PURCHASING CONFLICTS OF INTEREST  

A conflict of interest in purchasing arises when a faculty or staff member is or may be in the position to influence the university's business, research, or other decisions in ways that could lead to any form of personal gain for the faculty or staff member or others closely associated with that university employee. Further, except as part of official state duties, a UI employee shall not sell, in any one occurrence, any goods or services having a value in excess of two thousand dollars to any state agency unless the sale is made pursuant to an award or contract let after public notice and competitive bidding. Purchases from UI employees must be pre-approved by the Director of Purchasing.  

To review the complete policy, please see the UI Operations Manual.  

PROHIBITION OF GIVING AND RECEIVING GIFTS ("Gift Law") 

Under Iowa state law (Iowa Code Chapter 68B), public employees (which includes university employees) and members of their immediate family may not accept gifts valued at more than $3 from restricted donors (see policy for definitions of "gift" and "restricted donors"). "Restricted donors" includes supervisees and has been interpreted broadly to include students in one's classes and graduate student advisees.  

To review the complete policy, please see the UI Operations Manual.  

ROYALTIES FROM COURSE MATERIALS  

Faculty members should not profit from recommending or requiring the purchase of course materials by their students. Faculty members who receive royalties from the sale of course materials to their students should either refund the money to the students or make other arrangements to avoid profiting from their students' use of the materials (e.g., transferring the funds to the UI Center for Advancement).  

To review the complete policy, please see the UI Operations Manual.  

ANNUAL DISCLOSURE OF OUTSIDE PROFESSIONAL ACTIVITIES AND INTERESTS  

To ensure that UI academic, health care, business, research, and teaching endeavors are free of potential or actual conflicts of interest, the University of Iowa requires all University employees to disclose any potential or actual conflicts of interest in advance of initiating an activity or when the employee, in the exercise of reasonable diligence, first becomes aware of the conflict or the potential for one. Additionally, certain UI faculty and staff members are required to complete an Annual Disclosure of Outside Professional Activities and Interests by April 30th each calendar year.  

Please review to determine if you are a UI employee who is required to complete an Annual Disclosure of Outside Professional Activities.