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Introduction

In carrying out its primary missions of teaching, research and community service, the University must implement a diverse set of principles: maintaining academic freedom and an atmosphere that promotes free and open scholarly inquiry without bias; facilitating the transfer of technology and other developments for the benefit of the public; and serving as the steward of public and private resources entrusted to it.

The University recognizes the value of transferring technology and other activities to enhance public access to University research/scholarly activity and to further the economic development of the state and the nation. Additionally, participation by faculty and staff in external activities that enhance their professional skills or constitute public service may be beneficial to the University as well as the individual.

It is critical that business transactions and the design, conduct or reporting of research/scholarly activity not be biased or compromised by any conflicting financial interest or other potential or actual personal gain of an investigator or the University or one of its units. Failure to comply may jeopardize existing or future funding, and erode public trust.

The University recognizes that many potential conflicts of interest do not constitute actual conflicts or may be acceptable with proper oversight and safeguards.
The complexity and diversity of professional relationships has grown increasingly intertwined with outside entities in research and other University activities. Increased research support from private entities, changes in federal law and regulations encouraging technology transfer and the need for the University and its employees to demonstrate public accountability mandate new approaches in the discovery and management of potential conflict of interest situations. This may require reevaluation of previously acceptable activities. The most effective way to address conflict of interest is to establish a process by which employees disclose and obtain evaluation of potential conflict on a case by case basis.

To implement this process, the conflict of interest policy prescribes procedures for disclosure, review, and for the exercise of ongoing oversight where necessary. It also provides for review of decisions at higher levels of University administration. Lastly, it indicates the sanctions that may be applied when the policy is violated.

This policy applies to all University employees. As appropriate, subcontractors and other external collaborators must also comply with this policy unless their institution/company provides adequate assurances that they are in compliance with the federal regulations referenced above. This policy applies to any research, education or service activity regardless of whether or not support is provided to the University or employee. Support may be in the form of sponsorship, incentive, equipment or gift.

* This policy overlaps with but does not supplant University Employees' responsibilities under the Utah Public Officers' and Employees' Ethics Act, Utah Code Annotated ยง 67-16-1 et seq. (the Ethics Act), which in some instances may include additional reporting responsibilities. In many instances, this policy is broader than the Ethics Act in the situations covered. Also, incorporated by reference are the National Science Foundation Policy; Grant Policy Manual 510, Investigator Disclosure Policy, 60 F.R. 132, pp. 35810-823 (July 11, 1995), U.S. Department of Health and Human Services, Objectivity in Research Subpart F-Responsibility of Applicants for Prompting Objectivity in Research for Which Funding is Sought, 42 CFR Part 50, Subpart F and 21 CFR Part 54, Food and Drug Administration, Financial Disclosure by Clinical Investigators. As additional external federal policies are imposed, this policy will incorporate such new policies by reference.

Last Updated: 8/9/16