Members of the UVU community lead varied and exciting lives on- and off-campus. They engage with business, industry, private foundations, nonprofits, and government agencies in both volunteer and compensated roles. We celebrate vigorous engagement with the world beyond our institution, and enjoy corollary learning opportunities, collaborations, and reputational benefits. Indeed, we encourage employees to make the most of their multifaceted pursuits by remaining cognizant of potential conflicts of interest.
UVU's Compliance Office endeavors to assist employees with (1) identifying potential conflicts of interest and (2) strategically managing such conflicts. This process is preventive, not punitive. It aims to maximize the University's public confidence and the employee's professional credibility. It also helps to keep employees in compliance with the Utah Public Officers' and Employees' Ethics Act and UVU Policy.
For full-time employees, the COI disclosure is due annually by February 28th.
Full-time employees are required to disclose potential conflicts of interest annually (by 2/28) and upon hire.
All employees must disclose (1) immediately when a potential conflict first arises, (2) when asked to complete the form by their supervisor.
Full-time employees can review their COI disclosure data here. Supervisors will also see their full-time employees' data.
All employees must disclose actual, potential, and apparent conflicts of interest by completing 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 disclose upon hire and annually thereafter.
Conflict of Interest (COI) Disclosure Form
Supervisors receive an emailed copy of their employees' disclosures. They can also access their employees' disclosures with the dashboards at the top of this page. Supervisors must review their employees' disclosures of potential conflicts for omissions and for conflicts that could interfere with their employees’ university obligations (such as their time, resources, decision making, research, etc.). See Policy 114 5.2.5 and 5.3.1.
If the supervisor determines a disclosed conflict could interfere, they should work with both the employee and the University Compliance Officer to determine if the conflict is managable. Depending on the subject of the conflict, other departments may need to review the disclosure as well. For example, Office of Sponsored Programs, Procurement, People and Culture, etc.
University Policy 114 Conflict of Interest
Employees can resolve most apparent or potential conflicts of interest through thoughtful planning. If a conflict of interest is present, the employee and their supervisor must create a confidential COI Management Plan.
The COI Management Plan is not considered in place until signed by the Compliance Officer.
The top of this page has links for the disclosure as well as the full-time and part-time employee dashboards. The link is: https://qualtrics.uvu.edu/uvucoi.
Only full-time employees are required to complete the COI Disclosure Form annually. The due date is 2/28 of each year.
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 dashboards at the top of this webpage 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.
The COI training is no longer required. It is now an optional training, which you are encouraged to take to help answer any questions you may have when filling out the COI disclosure form. It is still located in UVULearn.
University Compliance at [email protected] or 801-863-5630.
Yes, if the textbook is approved and compliant with Policy 606.
Any questions regarding Policy 606 should be directed to Academic Administration, the stewards of the policy.
May I or my family earn income from self-authored materials that I assign?
Generally, no per Policy 606. To comply with Policy 606, most professors work with their publisher to NOT charge or provide royalties for self-authored materials sold to UVU students.
Any questions regarding Policy 606 should be directed to Academic Administration, the stewards of the policy.
No. Direct sale of course material is prohibited regardless of authorship per Policy 606.
Any questions regarding Policy 606 should be directed to Academic Administration, the stewards of the policy.
Not directly.
If a spouse or relative reports indirectly to you, you must disclose that reporting relationship on your COI Disclosure Form.
The reporting relationship then requires review and approval by People and Culture, as well as a management plan that states your agreement to not participate in any employment decisions about the relative.
Yes, but with a major restriction in the case of credit-bearing courses per Policy 114. The department chair or the dean must designate another appropriate employee such as a faculty member or teaching assistant to grade the student’s academic coursework (including papers, exams, projects, portfolios, and demonstrations) and assign a final grade for the course.
Practically speaking, the relative is attending your lectures and seeing your same course materials, but is being graded by an entirely different individual.
Generally, yes. Gifts greater than $50 are prohibited when
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.
See the travel website https://www.uvu.edu/travel/ for information on UVU travel and expense reimbursements.
May I accept compensation for presenting or serving on boards outside of UVU?
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 otherwise benefitting from the transaction (such as a kickback).
May I employ UVU students or offer internships through my outside business?
Yes, if the employment/internship is completely voluntary for the student and other requirements of Policy 114 are followed.
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.
Generally no. Employees may not leverage their UVU positions and UVU professional relationships to establish a customer base for their personal business or charitable activities. Utilizing their UVU position for personal benefit is prohibited by the Ethics Act.
Employees may engage in such activities outside of work hours and the workplace with individuals who happen to be members of the UVU community.
Generally no. Employees may not leverage their UVU positions and UVU professional relationships to establish a customer base for their families’ or friends’ businesses or charitable activities. Utilizing their UVU position for personal benefit is prohibited by the Ethics Act.
Employees may engage in such activities outside of work hours and the workplace with individuals who happen to be members of the UVU community.
Yes, in certain circumstances.
First, there must be no self-dealing per the Ethics Act. 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.
Second, a UVU department or unit may not purchase goods or services from a UVU employee if the employee’s UVU job fairly includes the provision of those goods or services. For example, a UVU employee should not be compensated (beyond normal compensation for their job) for conducting a software training when that employee’s UVU job duties include or relate to similar trainings.There is a faculty member in my department who engages in X commitment, and I am concerned it may be interfering with their UVU obligations. What do I do?
Although one of the most common questions, this is also one of the more complex ones.
Is the activity related to teaching, scholarship, or service? If so, any questions on if an employee should be participating in those activities should be determined by the employee's supervisor and/or academic reporting line (up to and including Academic Administration, if needed).
In general, though, Policy 635 Faculty Rights and Responsibilities as well as Policy 114 require that an employee's UVU obligations come first. Obligations such as holding class at the scheduled time, availability to students, attending department meetings, etc.
If this is a problem for your employee, many of these situations are worked through as employment concerns where the supervisor and/or the academic reporting line work with the employee. If necessary, employment measures such as Performance Improvement Plans, Notices of Improvement Needed, etc. can be implemented.
In cases where you need support, please feel free to reach out to University Compliance.
Is it a conflict of commitment for faculty to engage in scholarly activities?
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 creative works and in the publication, display, and exhibition of the results, subject to the acceptable performance of their other academic duties and compliance with state and federal regulations and university policy.” (section 4.6.3).
Moreover, “Faculty members have a responsibility to maintain their scholarly/creative competence and strive for improvement as needed (section 4.6.1)."
This sort of scholarly production and development will look different from discipline to discipline. Whether an activity is truly part of a faculty member’s UVU role is best determined by faculty and their academic reporting line who are familiar with the relevant discipline.
Any questions regarding Policy 635 should be directed to Academic Administration, the stewards of the policy.
Is it a conflict of commitment for faculty to engage in service?
No. Faculty are expected to engage in service as part of their role at UVU. Moreover, Policy 635 states that “Faculty members shall support their disciplines, professional organizations, and communities by participating in activities and groups that are directly related to their disciplines and to the mission of the University, including but not limited to service in professional societies, planning or chairing conferences or conference sessions, participating in peer review for their professional or discipline organizations, or reviewing materials for publication, exhibit, or performance, per department RTP criteria.” (section 4.7.6).
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 their academic reporting line who are familiar with the relevant discipline.
Any questions regarding Policy 635 or Policy 637 should be directed to Academic Administration, the stewards of the policies.
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.
As a general rule, 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 presumably pose an unmanageable conflict of commitment.
In the rare circumstances that an employee wishes to try and refute that presumption, an employee must demonstrate to their supervisory reporting line that this full-time employment would not interfere with their UVU obligations.
Outside employment or consulting must always be disclosed on the employee’s COI Disclosure Form.
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 per Policy 114. Similarly, full-time staff similarly may not engage in adjunct teaching without approval from their immediate supervisor.
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.
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, primarily with some professors not working during the summer. 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.
