An Institutional Conflict of Interest (ICOI) is a situation in which the University’s financial interests, its relationships with external entities or the external engagements of Covered University Officials (CUOs) could interfere with University business decisions or with the University’s core missions of research, scholarship and teaching.
University policy RI 11 establishes rules governing ICOIs and establishes the Institutional Conflict of Interest Committee (ICOIC). With the support of the COI Division, the ICOIC reviews Threshold University Transactions to identify ICOIs and recommend conflict management plans (CMPs). The CMPs are then recommended as advice to relevant Senior Decision Makers for approval.
Senior Decision Makers
Senior Decision Makers are Covered University Officials (CUOs) who receive advice from the ICOIC, typically in the form of a CMP and who are ultimately responsible for approving ICOI matters. This includes individuals who hold the below titles and their designates:
- Chancellor
- Provost
- Senior Vice Chancellor for Philanthropic and Alumni Engagement
- Senior Vice Chancellor for Business and Operations
- Senior Vice Chancellor for Research
- Senior Vice Chancellor and Chief Financial Officer
- Senior Vice Chancellor and Chief Legal Officer
- Senior Vice Chancellor for the Health Sciences
Examples of ICOIs
- An investigator proposes to conduct University human subject research that would test or evaluate University intellectual property that is licensed to an external entity.
- A CUO holds equity in a non-publicly traded company and the company proposes to sponsor University research.
- The University holds equity in a non-publicly traded company that proposes to sponsor a teaching position at the University.
For each of the above examples, the ICOI would review, confirm an ICOI exists, and recommend a CMP to the relevant Senior Decision Makers for approval.