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Conflicts of Interest and Related Disclosures

All employees of the University of Houston System have an obligation to adhere to the highest ethical standards of conduct reflected by state law, and university policy. This obligation encompasses a wide range of areas, including recognizing and disclosing potential conflicts of interest and conflicts of commitment, as well as disclosures related to procurement, export control laws, international relationships and technology transfer.

The University seeks to assist employees in adhering to these standards through providing information regarding the requirements for all employees, as well as specific groups of employees.

If this describes you:

More than one may apply You are required to:
All Employees

• Follow State Laws and University policies regarding Ethics, including Conflict of Interest and Conflict of Commitment

◦ Board of Regents Policy 57.01.2 – Code of Ethics
◦ SAM 02.A.29 – Ethical Conduct of Employees (Interim)

• Complete annual mandatory ethics training
Employees Involved in Procurement or Contract Management

• Refrain from participating in procurement or contracting activities if participation may create a conflict of interest with a private vendor
• Comply with all UHS purchasing procedures
• Comply with procurement conflict of interest requirements, including necessary disclosures 

◦ SAM 02.A.08 – Outside Activities/Interests Disclosures (Interim)

Full-time Exempt Employees Planning to Engage in:

• Outside paid professional activity (e.g., consulting)

• A startup company

• Certain outside board service

• Outside activity that reasonably appears to create conflict of interest or conflict of commitment

• Complete the Outside Activities Form unless the activity is pre-approved, and receive approval prior to starting the work.*

◦ Board of Regents Policy 57.01.2 – Code of Ethics
◦ SAM 02.A.08 – Outside Activities/Interests Disclosures (Interim)
◦ Outside Activities Frequently Asked Questions (FAQs)
◦ Outside Activities Considerations for Supervisors Reviewing Forms

 

Research Investigators

• Comply with University policies regarding research and sponsored projects, including conflict of interest
• Comply with all requirements of any sponsoring agency
• Make financial disclosures as per University research policies 

◦ Policy on Conflict of Interest in Research
◦ Integrated Compliance Oversight Network (ICON) portal  

Employees with International Collaborators/Donors

• Comply with all requirements of any sponsoring agency
• Comply with export control laws and federal disclosure requirements regarding foreign components and reporting

◦ SAM 01.D.17 – Export Controls

* This requirement is still applicable even if the employee has already started the outside activity.