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Conflict of Interest Procedures: Difference between revisions
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[[Human Resources]] | [[Safety/Security]] | [[Research Compliance]] | '''[[Compliance]]''' | [[Privacy/Information Security]] | [[Business Operations]] | [[Intellectual Property]] | [[Human Resources]] | [[Safety/Security]] | [[Research Compliance]] | '''[[Compliance]]''' | [[Privacy/Information Security]] | [[Business Operations]] | [[Intellectual Property]] | ||
<br /><br /> | <br /><br /> | ||
[[Compliance Program]] | [[Compliance Hotline]] | [[Investigations by Third Parties]] | [[Research Integrity]] | [[Export Control]] | [[Code of Conduct]] | [[Use of Human Anatomical Material]] | [[Clinical Trial Professional and Technical Fee Billing]] | [[Contracts]] | [[Conflict of Interest]] | [[Red Flag Identity Theft Prevention Program]] | [[Principles of Financial Stewardship]] | [[Human Tissue Use and Transfer]] | [[International | [[Compliance Program]] | [[Compliance Hotline]] | [[Investigations by Third Parties]] | [[Research Integrity]] | [[Export Control]] | [[Code of Conduct]] | [[Use of Human Anatomical Material]] | [[Clinical Research and Clinical Trial Professional and Technical Fee Billing]] | [[Contracts]] | [[Conflict of Interest]] | [[Red Flag Identity Theft Prevention Program]] | [[Principles of Financial Stewardship]] | [[Human Tissue Use and Transfer]] | [[Disclosing Foreign Support and International Activities]] | [[Health Care Vendor Interactions]] | [[Credit Hour Definition]] | [[Whistleblower]] | ||
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<big>Business Conflict of Interest Procedures | '''<big>Business Conflict of Interest Procedures </big>''' | ||
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== Definitions == | ==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 | '''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.<br /> | ||
'''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.<br /> | |||
'''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. | ||
'''Covered Person' | |||
== Examples of Conflicts of Interest == | == Examples of Conflicts of Interest == | ||
===Seeking/Accepting Gifts=== | ===Seeking/Accepting Gifts=== | ||
No Covered Person will seek or accept anything of value given which could influence | 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 | 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=== | ===Improper Use of Office or Position=== | ||
No | 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. | * Attempting to influence, directly or indirectly, the relationship between the University and an organization in which the individual has interest. | ||
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A Covered Person who proposes to engage in an activity that would create a situation defined as a COI shall complete an [https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire]. | A Covered Person who proposes to engage in an activity that would create a situation defined as a COI shall complete an [https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire]. | ||
== Management of Potential or Actual Conflict of Interest == | == 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: | The following is a list of possible management strategies to manage the potential or actual conflict of interest: | ||
# No action beyond disclosure of the COI. | # No action beyond disclosure of the COI. | ||
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==Additional Information== | ==Additional Information== | ||
* | *Contact the [mailto:sarah.glodencarlson@unmc.edu Chief Compliance Officer] | ||
*Contact the [mailto:annebarnes@unmc.edu Vice Chancellor for Business, Finance and Business Development] | |||
*UNMC Policy No. 8010, [[Conflict of Interest]] | *UNMC Policy No. 8010, [[Conflict of Interest]] | ||
*UNMC Policy No. 1049, [[Outside Employment]] | *UNMC Policy No. 1049, [[Outside Employment]] | ||
*UNMC Policy No. 8014, [[Disclosing Foreign Support and International Activities]] | |||
*[https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire] | *[https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire] | ||
*[[Research Conflict of Interest Procedures]] | *[[Research Conflict of Interest Procedures]] | ||
*[https:// | *[https://wiki.unmc.edu/index.php/Conflict_of_Interest#Policy_8010_Appendix_A Conflict of Interest Committee Governance] | ||
*[https://unmc.coi-smart.com Application for Authorization to Engage in Outside Professional Activities] | |||
This page updated | This page updated by [mailto:dpanowic@unmc.edu dkp].<br /> | ||
Last Review and Revision by Policy Owners: March 13, 2023 | |||