Conflict of Interest Procedures

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Business Conflict of Interest Procedures

Definitions

Conflict of Interest refers to situations when the employee’s personal financial interests or fiduciary duties owed to third parties, such as immediate family, may compromise, or have the appearance of compromising, the employee’s professional judgment or behavior in carrying out their obligations to the University of Nebraska Medical Center.
Immediate family shall mean wife, husband, children, grandchildren, parents, grandparents, brother, sister, daughter-in-law, son-in-law, guardian, ward, stepfather, stepmother, stepchildren, or persons bearing the same relationship to the spouse of the employee.
Covered Person refers to faculty, staff, volunteers, trainees, students, independent contractors and other persons whose conduct, in the performance of work for UNMC, is under the direct control of UNMC, whether or not they are paid by UNMC.

Examples of Conflicts of Interest

Seeking/Accepting Gifts

No Covered Person will seek or accept anything of value given which could influence them in the discharge of official duties. For example, acceptance of a valuable gift or service from an organization with which the university is, has or will be negotiating an agreement or conducting business, would be a conflict of interest. Gift does include a breakfast, luncheon, dinner, or other refreshments consisting of food and beverage provided for immediate consumption.

UNMC does not permit Covered Persons to solicit UNMC vendors, other UNMC employees or UNMC departments for contribution or purchase of prizes, favors, awards, drawings, or anything of value. The annual United Way fund drive is exempted from this policy. Prior written approval of any other exemption to this policy may be granted in exceptional circumstances by the Vice Chancellor for Business, Finance and Business Development or their designee.

Improper Use of Office or Position

No Covered Person will knowingly use an official position to obtain special privileges or advantages from individuals or businesses except as specifically provided by the Board of Regents policy. Examples include but are not limited to the following:

  • Attempting to influence, directly or indirectly, the relationship between the University and an organization in which the individual has interest.
  • Disclosure of confidential information concerning university-owned technology to an organization for personal profit and advantage (possibly in violation of confidentiality obligations to research sponsors or licensees).

Commercial Transactions

No Covered Person may sell, or cause to be sold, either as an individual or through any business enterprise in which that individual holds a substantial financial interest, any goods or services unless approved by the Vice Chancellor for Business and Finance or appointed designee.

For example, a Covered Person may not purchase services or equipment from an organization in which the Covered Person has a financial interest, has a consulting or other arrangement providing income to the Covered Person and/or on whose board the Covered Person serves.

Purchasing of Goods or Services from Immediate Family Members

No Covered Person may purchase, or cause to be purchased, on behalf of the UNMC any good or services directly or indirectly from an immediate family member under Board of Regents policy 6.2.1 Sec.11. Any such purchase would be considered a conflict of interest.

Immediate family members of a Covered Person are not barred from such sales of goods or services; such conflicts can be managed when the authorized decision maker to purchase such goods or services is an employee with no conflict of interest in the purchase and not subordinate to the employee with the conflict of interest.

Service on External Non-profit, Governmental or For-profit Governance Boards

A Covered Person may serve on external non-profit, governmental or for-profit governance boards, however if such service in any way could create an actual or perceived conflict of interest, the services must be declared and managed by the employee’s supervisor.

Outside Employment or Compensation

No Covered Person may receive or solicit outside employment, including paid service on a governance board, or compensation that would impair the independence of judgment of the individual in performing duties as an employee of UNMC. Refer to UNMC Policy No. 1049, Outside Employment.

Reporting Potential Conflict of Interest

A Covered Person who proposes to engage in an activity that would create a situation defined as a COI shall complete an Annual Disclosure of Financial Interest Questionnaire.

Management of Potential or Actual Conflict of Interest

The following is a list of possible management strategies to manage the potential or actual conflict of interest:

  1. No action beyond disclosure of the COI.
  2. Sever the relationship between the Covered Person and the organization that causes the conflict.
  3. The supervisor can be the decision maker or delegate the decision for the purchase of goods or services, instead of the Covered Person, in order to eliminate any conflict.

Additional Information

This page updated by dkp.
Last Review and Revision by Policy Owners: September 15, 2021