University of Rochester

Working at the University

Code of Conduct for Business Activities

II. A) Conflict of Interest

1. Policy

It is the University's intent to avoid conflicts and the appearance of conflicts between interests of the University and the personal interests of faculty and staff members. Therefore, when any University business transaction under consideration presents the potential for a conflict of interest, or the appearance of one, the faculty or staff member concerned shall not be involved in the transaction, and the University shall act in accordance with the following guidelines and procedures.

2. Guidelines

a) A potential for a perceived or actual conflict of interest in a University business transaction exists where a University faculty or staff member, or a close relative or member of that person's household, is an officer, director, employee, proprietor, partner, trustee or stockholder in, or stands personally to profit from an organization seeking to do business with the University.

b). A potential actual or perceived conflict exists when a University faculty or staff member has an interest in an organization which is in competition with a firm doing business with the University and if the faculty or staff member's position gives him/her access to proprietary or other privileged information which could benefit the firm in which he/she has an interest.

c). University business transactions include but are not limited to procurement of goods and services (including consulting and contractual services), disposition of University materials or property, and agreements for the provision of services or use of University facilities or space.

d). Involvement in a University business transaction includes but is not limited to initiating, making the principal recommendation for, or approving a purchase or contract; drafting or negotiating the terms of a transaction; or authorizing payments for University accounts.

3. Procedures

a). Any University faculty or staff member who is or is to be involved in a University business transaction in which a potential for conflict of interest or its appearance exists, on his or her own part or on the part of another University person, is required to promptly report such potential conflict as described in section I. B) of this Code.

b). The University shall take action to assure that the transaction, if it is to proceed, is on fair and reasonable terms and in the best interest of the University. Someone other than the individual with the conflict shall make the necessary decisions and control the transactions. The resolution shall be communicated to the relevant Dean, Director or Vice President.

c). The best interest of the University does not mean that purchases or other transactions must necessarily be diverted to other sources.

The following University of Rochester policies relate to this Conflict of Interest policy:

Faculty Policy on Conflict of Interest
Policy on Intellectual Property and Technology Transfer
Conflict of Interest (Business Transactions)
Potential Conflict of Interest (Purchasing Services Statement of Business Practices, Section 1.5)
Federal Requirements Regarding Financial Disclosures and Agency Notifications
SMH Policy 1.7, Code of Organization and Business Ethics
SMH Policy 7.9, Pharmaceutical Company Representatives

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