INSTITUTIONAL CONFLICT OF INTEREST

SECTION I. SCOPE.

This policy governs institutional conﬂict of interest at the University of Minnesota (University) and applies to members of the Board of Regents (Board), University ofﬁcials, department/unit heads, and other individuals as required by administrative policies and procedures.

SECTION II. DEFINITIONS.

Subd. 1. Institutional Conﬂict of Interest. Institutional conﬂict of interest shall mean a situation in which the research, teaching, outreach, or other activities of the University may be compromised because of an external ﬁnancial or business relationship held at the institutional level that may bring ﬁnancial gain to the institution, any of its units, or the individuals covered by this policy. Subd. 2. University Ofﬁcial. University ofﬁcial shall mean persons holding the following positions, including those holding these positions in a temporary capacity:

(a) chancellors and vice chancellors;
(b) deans, associate deans, and assistant deans;
(c) division I athletic director;
(d) general counsel;
(e) president and president’s chief of staff;
(f) provosts, vice provosts, associate vice provosts, and assistant vice provosts; and
(g) senior vice presidents, vice presidents, associate vice presidents, and assistant vice presidents.

SECTION III. GUIDING PRINCIPLES.

The following principles shall guide the University in addressing institutional conﬂict of interest:

(a) Because it is critical to the mission and reputation of the University to maintain the public’s trust, University research, teaching, outreach, and other activities must not be compromised or perceived as biased by ﬁnancial and business considerations.

(b) Because of its numerous and complex relationships with public and private entities, the University must be aware of any relationships involving ﬁnancial gain that may compromise or appear to compromise its integrity.

(c) The University shall establish and maintain an oversight process to manage, reduce, or eliminate institutional conﬂict of interest.

SECTION IV. RESERVATION OF AUTHORITY.

The Board reserves authority to review and approve plans for managing, reducing, or eliminating institutional conﬂict of interest involving:

(a) external relationships with an unusually signiﬁcant ﬁnancial impact that present a potential conﬂict;
(b) potential conﬂicts involving the president;
(c) potential conﬂicts that raise serious policy issues or have a signiﬁcant public impact on the mission and reputation of the University; or
(d) potential conﬂicts arising in matters that otherwise require Board review and action under Board of Regents Policy: Reservation and Delegation of Authority.

In these instances of conﬂict of interest, the president shall consult with the Board.

SECTION V. ASSURANCE, DELEGATION OF AUTHORITY, AND REPORTING.

The president or delegate shall:

(a) implement an oversight process and administrative policies and procedures to address institutional conﬂict of interest and to identify situations in which institutional conﬂict of interest may arise;
(b) recommend and implement plans to manage, reduce, or eliminate institutional conﬂict of interest;
(c) develop a nd present conﬂict of interest plans to the Board for review and action as required under Section IV;
(d) ensure that individuals covered by this policy who act on behalf of the institution adhere to these policies and procedures, follow applicable conﬂict management plans, and do not engage in activities in which there is an actual conﬂict of interest; and
(e) report to the Board annually all institutional conﬂict of interest matters that do not meet the thresholds identiﬁed in Section IV.

SECTION VI. DISCLOSURES.

Subd. 1. Regents. Regents shall ﬁle a ﬁnancial disclosure statement annually and report conﬂicts of interest as required by Board of Regents Policy: Code of Ethics.

Subd. 2. University Ofﬁcials. University ofﬁcials shall, upon appointment and annually on September 30 thereafter, ﬁle a ﬁnancial disclosure statement with the president or delegate, disclosing signiﬁcant economic interests and how those interests may relate to their institutional responsibilities. Such disclosure shall be made in addition to any reporting requirement for individual conﬂicts of interest.

Subd. 3. Department/Unit Heads. Annually and under circumstances described in administrative policy, department/unit heads shall disclose relevant ﬁnancial and business interests by ﬁling a Report of External Professional Activities.

Subd. 4. Other Individuals. The president or delegate may designate other individuals who shall ﬁle a ﬁnancial disclosure statement.

SUPERSEDES: FINANCIAL DISCLOSURE FOR SENIOR UNIVERSITY OFFICIALS, DATED NOVEMBER 10, 1995.