Conflict of Interest

A conflict of financial interest arises whenever decisions made as an OU employee are affected, or can reasonably appear to be affected, by the financial interests of the employee or close relatives.  These conflicts can range from trivial (“I am choosing a new file cabinet for our office and one of the mutual funds in my retirement portfolio includes stock in a furniture company”) to very serious (“I am awarding a $100,000 subcontract on a sponsored-research grant, and the best option is my own company”).  The Regents’ Policy on Conflicts of Interest, along with related policies, provides guidelines on what interests and relationships do not create a conflict, what conflicts need a management plan, and what conflicts cannot be permitted.

Non-OU employment or consulting may create a direct financial conflict of interest, for example if the employment is with a company that also funds one’s OU research, or hires one’s own students, or competes with OU for research funds in the employee’s area of responsibility.   Even when there is no direct financial relationship between it and one’s OU position, outside employment may affect the amount of time available for OU duties, may create contractual obligations inconsistent with OU duties (e.g. publication embargo), and, in the case of other academic positions, may create inconsistent obligations with regard to such matters as authorship and advising of students.  Not all outside employment creates a conflict, but employment in the area of one’s OU duties typically requires disclosure and review. 

State ethics rules prohibit the use of one’s position to provide any improper personal benefit for oneself, a family member, or another individual.  A conflict arises and requires disclosure whenever any personal interest or relationship — financial or not — reasonably appears to affect one’s OU duties.  For example the hiring, supervision, or evaluation of one’s own family members is addressed by OU’s nepotism policy.  Teaching or advising one’s own family members can also require disclosure and management.  It may create a conflict to serve in any capacity that requires impartiality— tenure evaluation, search committees, etc. — toward individuals to whom impartiality cannot reasonably be expected.

It is generally prohibited to use OU resources (equipment, vehicles, computers, staff time, lab or classroom space, etc.) for personal purposes.  OU’s policies provide exceptions for truly trivial and incidental use, and for rental and other situations in which OU receives the fair market value of the resource.

Training and Disclosure

Employees shall complete disclosures on an annual basis or with any change in circumstance. Conflict of Interest training shall be completed every 4 years.  New employees shall complete training and disclosures within 30 days of hire.