Full-time employees must complete the COI Disclosure Form each year by February 28th (the same deadline as UVU’s required trainings). The form from the previous year is no longer effective as of March 1.

If you completed the form on 2/27/24, then the dashboard would show you as incomplete as of 3/1/24 and you would have to complete the form again sometime between 3/1/24 and 2/28/25.

All employees must complete the COI Disclosure Form (1) immediately when a conflict of interest first arises and (2) when asked to complete the form by their supervisor.

Additionally, all employees, with the exception of part-time employees (including student employees and adjunct faculty members), must submit a Conflict of Interest Disclosure Form at the time of hire and annually thereafter. In other words, ONLY full-time employees must disclosure upon hire and annually thereafter.

Supervisors, per Policy 114, are responsible for identifying and broaching any conflict of interest or commitment concerns with the employee and Compliance Officer. The entire Conflict of Interest disclosure, review, and management process depends on the active engagement of supervisors. Supervisors know their employees’ UVU roles and activities, and, ideally, have established relationships built on genuine care. Given their unique position, supervisors should help their employees spot and avoid situations that present conflict of interest concerns.

Once aware of a concern, supervisors should reach out to University Compliance to help evaluate whether a potential conflict exists and how it ought to be managed/avoided. Immediate supervisors are responsible for reviewing their employee’s disclosures and raising any concerns with the employee and University Compliance. This includes verifying that potential conflicts known to the supervisor are disclosed on an updated COI Disclosure Form. Caring supervisors help their employees avoid trouble and find solutions to potential pitfalls.

Supervisors should visit the Supervisor COI Dashboard periodically to ensure they’re up to date on their employees’ disclosure concerns, questions, and compliance status.

Not necessarily. In fact, most disclosures from UVU employees are not conflicts. Please answer the COI Disclosure Form questions honestly and completely, even if you don’t think your response could be a conflict of interest or commitment. Your supervisor will review and raise any concerns with you and with University Compliance. You, your supervisor, and University Compliance will evaluate whether a potential or actual conflict is present and how to manage it.

In the vast majority of cases, potential conflicts are easily manageable and do not require a prohibition on the outside activity.

University Compliance at [email protected] or 801-863-5630.

No. “Except for reimbursement of out-of-pocket costs, faculty and employees may not accept or retain royalties or any other personal compensation or material benefit from the sale or furnishing of course materials they authored to students in their own classes, in any classes in their department, or department/college for which they have authority to assign or recommend course materials. They may, however, designate such royalties or compensation into a department-wide fund, as approved by the college/school dean in consultation with the university Compliance Officer” (see Policy 606, section 5.2.3).

Generally, yes. Gifts greater than $50 are prohibited when

1. they would “tend to improperly influence a reasonable person” to depart from faithful and impartial performance of their job. Reimbursing ordinary airfare, food, and hotel are generally not regarded as so extraordinary that it would improperly influence the recipient.
2. the employee “recently has been, is now, or in the near future may be” involved in any UVU action directly affecting the donor. If you will make decisions about a specific vendor’s contract with UVU, it’s best to avoid any gift from that vendor above $50.

Not if you are presenting or attending on behalf of UVU (i.e., it’s part of your job). If you are presenting or attending in your personal capacity or as a non-UVU consultant then yes, you should take personal leave or approved consulting leave. If it’s a combination of the two (such as pre-approved personal days in the city following your conference), take personal leave only for the personal days.

Yes. You may accept compensation for non-UVU service and speaking engagements, so long as you are not acting as a spokesperson or representative of UVU. Just because the host identifies you as a UVU employee does not mean you are presenting or serving on behalf of UVU.  In the unusual circumstance where outside compensation is offered for performing your UVU duties on behalf of UVU, the compensation properly belongs to UVU and appropriate UVU personnel should decide how it is allocated.

Generally no. The Utah Public Officers' and Employees' Ethics Act prohibits employees while acting in their official UVU capacity (such as deciding to buy from a company) from participating, or receiving compensation as a result of, a transaction between UVU and a business entity "of which the public officer or public employee is an officer, director, agent, employee, or owner of a substantial interest..." A board member is included within the definition of officer, director, and agent.

This would only be allowable if your supervisor or someone who does not report to you independently made the decision to buy from that company.

Keep in mind that some companies call you a board member when in reality you are serving as a focus group / feedback source. This prohibition doesn't apply in these cases where you aren't representing their company, assuming also that you aren't getting a kickback or otherwise benefitting from the transaction.

Yes, if the employment/internship is completely voluntary for the student. It is a conflict of interest for a faculty or staff member to use their UVU position to assign students to work for their non-UVU business or personal interest. Faculty members, moreover, may not consider student-intern/employee performance as a factor in assigning UVU course grades for that student. A faculty member’s UVU courses and outside interests must remain separate, and student involvement in an employee’s non-UVU interests must be voluntary.

Arranging internship opportunities through the UVU Office of Internship Services, where the employee’s internship is just one among many options for students, is a good way to diminish conflict concerns. 

A management plan is required if you will be employing UVU students who are also enrolled in one of your courses.

Yes, in certain circumstances.

First, there must be no self-dealing. An employee-UVU transaction is permissible only if the employee selling the goods/services does not hold a position at UVU where they can influence or participate in the transaction in their official UVU capacity. For example, they cannot be a part of the procurement approval process, such as the Index responsible party. An employee whose UVU job includes selecting food vendors for special events may not sell cookies to UVU for special events.

No. Faculty are expected to engage in scholarship as part of their role at UVU. Faculty members, of course, may not neglect their teaching responsibilities to engage in scholarship. Policy 635 says “faculty members are entitled to full freedom in research and in the publication of the results, subject to the acceptable performance of their other academic duties” (section 4.3.1). “Faculty members,” moreover, “have a responsibility to develop and improve their scholarly/creative competence” (section 4.3.2).

No. Faculty are expected to engage in service as part of their role at UVU. Moreover, Policy 635 states that “faculty members are expected to participate in the academic organizations and professional communities of their disciplines” (section 4.4.1).

Faculty members, of course, may not neglect their teaching and other responsibilities to engage in service. Policy 637 Faculty Tenure refers to “service” as “service activities at the University, to one’s profession, and in the community that are clearly related to the faculty member’s role” (section 3.7). This looks different from discipline to discipline.

Whether an activity is truly part of a faculty member’s UVU role is best determined by faculty and academic administrators who are familiar with the relevant discipline.

There is no one-size-fits-all. Employees may engage in non-UVU professional and personal commitments. Employees must ensure, however, that non-UVU activities don’t interfere with the performance of their UVU duties or their ability to work the hours required for their position. Full-time employees are expected to work at least 40 hours per week on their UVU job duties. For faculty, this includes teaching, teaching preparation, office hours, attending department and college meetings, scholarship, and service.

Non-UVU activities must not require such extensive time or absence as to cause a faculty member to neglect course obligations, become unavailable to students or colleagues (including office hours and department meetings), or otherwise violate Policy 635 Faculty Rights and Professional Responsibilities. These are case-by-case judgments, as each department has nuanced demands and expectations.

Some outside activities are an expected and encouraged part of certain employees’ university roles. For example, our policies encourage faculty involvement in related scholarly and service opportunities (e.g., conference participation) that will enhance knowledge/expertise and improve the quality of teaching at UVU. Other outside engagements, such as adjuncting at another institution or pursuing personal hobbies, are really “non-UVU” in nature, and therefore may compete with UVU time commitments.

No. For full-time employees, including full-time faculty members, engaging in outside full-time employment (or a combination of part-time work equivalent to full-time employment) would pose an unmanageable conflict of commitment.

Outside part-time employment for full-time UVU employees is generally discouraged but not prohibited. Part-time employment would create a conflict of commitment if it interferes with an employee’s performance of their UVU duties or requires special scheduling accommodations (such as never being available on a certain days of the business week or for department meetings). Employees should schedule any outside employment or business activities around their UVU obligations. UVU should not be harmed or inconvenienced in order to accommodate its employees’ unavailability due to outside employment and business activities.

Outside employment or consulting must always be disclosed on the employee’s COI Disclosure Form.

Full-time faculty may not engage in adjunct teaching at another academic institution during their UVU teaching semesters without approval from the relevant dean. Similarly, full-time staff similarly may not engage in adjunct teaching without approval from their immediate supervisor, and, if at UVU, the dean of the college where they intend to teach.

When permissible, adjuncting at other academic institutions must not interfere with the employee’s performance of their UVU duties, require special scheduling accommodations, or otherwise create a conflict of interest. This is a non-UVU activity and must be balanced against the primary time commitment at UVU. Factors such as number of course hours, online versus face-to-face, flexibility on timing (evenings/weekends), and distance from delivery location are relevant considerations.

Outside adjuncting engagements must be disclosed on the employee’s COI Disclosure Form.

Yes. Consulting activities, however, may not interfere with the performance of an employee’s UVU duties such as attending and preparing for scheduled classes, office hours, and departmental meetings. Sometimes consulting and scholarship/service are combined in a single endeavor (see FAQs above), which may help diminish the potential for a conflict of commitment and justify the use of “consulting leave.”

Up to two days/month of paid consulting leave may be available for employees to engage in consulting (i.e., acting in an advisory capacity for a short period of time) during normal work hours or on campus. Employees wishing to use consulting leave must demonstrate that use of consultation release time has a demonstrable relationship to the employee’s professional interests and the University’s interests, and obtain supervisor approval via the Request for Consultation Form (Policy 323, section 4.1.2). See Policy 323 Guidelines for Consulting and associated guidelines for more detail on the approval process and requirements.

Consulting engagements must always be disclosed on the employee’s COI Disclosure Form.

Yes. UVU employees may engage in non-UVU activities including community service positions, religious positions, political positions, and others. However, these positions may not interfere with the employee’s ability to carry out the duties of their UVU position.

Faculty teaching schedules vary during the year. This is an important factor in determining whether a non-UVU activity presents a conflict of commitment. Generally, summer schedules allow for more vigorous engagement in UVU scholarship, service, and non-UVU activities.