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Examples of activities and situations that present, or may appear to present, potential conflicts of interest include, but are not limited to:

1. Situations in which financial, professional, or other personal considerations may directly or indirectly affect, or have the appearance of affecting, an employee鈥檚 professional judgment in exercising any university duty or responsibility in administration, management, instruction, research, or other professional activities. This can include interests that bias the nature or direction of scholarly research or influence decisions with respect to teaching and students, appointments and promotions, use of university resources, interactions with human subjects, or other matters of interest to the university.
2. Situations in which outside relationships or activities interfere with, or have the appearance of interfering with, an employee鈥檚 commitment to their university duties or responsibilities.
3. An employee鈥檚 external personal entity utilizes, supports, or funds their sponsored research.
4. An employee purchases via university or sponsored research funds any goods or services from his/her external personal entity.
5. An employee鈥檚 external personal entity licenses intellectual property to, or otherwise profits from, sponsored research.
6. An employee subcontracts any aspects of his/her sponsored research to his/her external personal entity.
7. An employee鈥檚 Significant Interest in his/her external personal entity could directly and significantly affect the design, conduct, or reporting of their sponsored research or educational activities.
8. Diversion of university business opportunities to an external entity.
9. Assignment of students or graduate assistants to duties that benefit an external entity in which the person in charge of assignment of those duties has a Significant Interest.
10. Use of university facilities, supplies, or personnel for the benefit of an external entity in which the employee has a Significant Interest.
11. Assumption of responsibilities for an external organization that divert a university employee from his/her attention to university duties, or create other conflicts of loyalty.
12. Use for personal profit of unpublished information emanating from university research or other confidential university sources, assisting an external organization by giving it exclusive access to such information, or consulting under arrangements that impose obligations that conflict with university patent policy or with the university鈥檚 obligations to research sponsors.
13. Conduct of research that could and ordinarily would be carried on within the university elsewhere to the disadvantage of the university and its legitimate interests.

All baby直播app and any other employee or student with responsibility for the purpose, design, conduct or reporting of research are considered essential to the research process and must disclose any significant financial interest and external professional activity that could compromise or appear to compromise their judgment in performing their university duties or responsibilities. It is not for each individual researcher to decide if he/she must report based on a belief that no conflicts exist.

All baby直播app includes Tenured and Tenure-track baby直播app; Teaching Professors (all levels); Instructors (all levels); Lecturers; Adjunct, Visiting, and Research baby直播app; retired baby直播app if engaged in research activities at CU Boulder; Professional Research Assistants, Research Associates, and Research Assistants. TAs and Adjoint Faculty typically do not need to submit the DEPA unless they are engaged in research activities. The disclosure requirement applies to full time and proportional appointments. Non-university employees such as collaborators, consultants, subcontractors, and volunteers may be required to submit the DEPA or to certify disclosure at another institution, depending upon funding agency requirements.

If you are engaged in one or more of the following activities,听you are required to submit听the DEPA:

• Directing, overseeing, or supervising the research process and/or research personnel
• Participating in theory development and testing
• Participating in the design and development of research protocols, experiments, tests, or other means of data collection
• Participating in sample design and selection
• Participating in the collection or analysis of data or the reporting of results
• Enrolling human subjects or participating in the informed consent process
• Intervening with human subjects by performing research procedures or manipulating the environment for research purposes
• Having access to personally identifiable study data

If you are engaged in only the following activities,听you are not required to submit听the DEPA:

• Performing data entry or statistical analysis on data sets without involvement in research design, sample selection, data collection, or reporting of results
• Participating in the recruitment of research subjects without any involvement in enrollment
• Interacting with research subjects without performing a procedure or intervention for research purposes
• Participating in the acquisition, monitoring, and maintenance of materials, supplies, and equipment without engaging in their use for research purposes
• Performing language translation of research-related documents, including survey instruments
• Hiring and training research personnel

In addition,听the following groups are required to submit听the DEPA:

• Librarians and Museum Associates and Fellows
• Research Committee Members (i.e., IRB members, IACUC members and/or other research review committees)
• Staff who negotiate or execute research agreements on behalf of CU Boulder: Area/Program Administrators, Office of Contracts and Grants staff members, and Venture Partners at CU Boulder staff members
• Office of Research Integrity staff members

The PD/PI and any other person identified as Senior/Key Personnel by the institution in the grant application, progress report, or any other report submitted to a grant sponsor by the university.

Key Personnel includes any individual involved in research and who is supported in salary, supplies, space, or other resources by grant funding.

You do not need to disclose the following:

• A personal or financial interest unrelated to your institutional responsibilities
• A financial interest that does not exceed the thresholds
• Salary, royalties, or other remuneration paid by the university if you are currently employed or otherwise appointed by the university, including intellectual property rights assigned to the university and agreements to share in royalties related to such rights
• Income from investment vehicles, such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made in these vehicles.
• Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education
• Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education
• Travel that is reimbursed or sponsored by the university; a U.S. federal, state, or local government agency; another U.S. institution of higher education; a U.S. academic teaching hospital, medical center, or research institute that is affiliated with a U.S. institution of higher education

A听Financial Interest received from or held in an entity outside of the university that reasonably appears to be related to your Institutional Responsibilities and that meets or exceeds the thresholds established in accordance with current funding agency regulations (including the PHS regulations reflected at 42 CFR Part 50, Subpart F):

1. With regard to any publicly traded entity, value of any Remuneration received from the entity in the twelve (12) months preceding the Disclosure and the value of any Equity Interest in the entity as of the date of Disclosure, when aggregated, exceeding $5,000.
2. With regard to any non-publicly traded entity, value of any Remuneration received from the entity in the twelve (12) months preceding the Disclosure exceeding $5,000, OR any Equity Interest.
3. Intellectual Property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
4. Travel reimbursement or sponsorship to a U.S. destination valued at more than $2,500 when aggregated per entity over the previous 12 months or to a foreign destination of any value (except travel that is reimbursed or sponsored by the University of baby直播app; a U.S. federal, state, or local government agency; another U.S. institution of higher education; a U.S. academic teaching hospital, medical center, or research institute that is affiliated with a U.S. institution of higher education)

The term 鈥淪ignificant Financial Interest鈥� does NOT include:

1. Salary, royalties, or other remuneration paid by the university to the Discloser if the Discloser is currently employed or otherwise appointed by the university, including intellectual property rights assigned to the university and agreements to share in royalties related to such rights.
2. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Discloser does not directly control the investment decisions made in these vehicles.
3. Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education.
4. Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); a U.S. academic teaching hospital, medical center, or a research institute that is affiliated with a U.S. institution of higher education.
5. Travel that is reimbursed or sponsored by the university; a U.S. federal, state, or local government agency; another U.S. institution of higher education; a U.S. academic teaching hospital, medical center, or research institute that is affiliated with a U.S. institution of higher education.

The university鈥檚 report of a Financial Conflict of Interest to a PHS Awarding Component.

For the purposes of this policy, any family member with whom you have a close relationship that could cloud your judgement. Family members include, but are not limited to, spouse, parents (yours or spouse鈥檚), child, sibling, son/daughter-in-law, step relatives, domestic partner, and/or relatives of domestic partner in any relationship stated above.

(厂别别听Policy & Standards.)

Significant Interests are reported electronically via the DEPA Form.

The COIC Office has transitioned to a new InfoEd reporting system, which included a revamp of the DEPA Form.

1. To access the DEPA Form, please follow the below steps:
   1. Go to .
   2. Select Boulder from the campus drop-down menu.
   3. Enter your IdentiKey and Password.听Click Log in.
   4. Click DEPA Form in the left-side menu on the Home page.
   5. Click Create/Update DEPA Form when the screen refreshes.
2. To view your previous DEPA submissions, please follow the below steps:
   1. Log into .
   2. Employees: Under CU Resources, select the Faculty Reporting & DEPA tile.
   3. Students: In the Buff Portal, open the search function by clicking the menu icon in the top left corner of the page, then search 鈥淒EPA鈥� and select the link.
   4. Click Log into DEPA.

A document developed by the COIC Office and approved by the applicable Supervising Authority to (1) obtain information and commitments regarding Significant Interests and prevent such Significant Interests from developing into Conflicts of Interest, and/or (2) Manage Conflict(s) of Interests for a particular Discloser.

• The Management Plan may address the areas of university responsibilities implicated, including:
  
  1. Objectivity and scientific integrity, including Disclosure of a Discloser鈥檚 Conflict in publications and presentations;
  2. Objective treatment of students and/or subordinates;
  3. Objective treatment of, and scientific integrity with respect to, human subjects;
  4. Decisions regarding the development, Disclosure, and use of university Intellectual Property;
  5. Decisions regarding the decision to purchase products or services;
  6. Decisions regarding the use of the Discloser鈥檚 time as well as other resources of the university; and
  7. Decisions regarding the appropriate rate to charge an outside entity for services performed by university employees.

Yes, you may engage in outside work under certain conditions. However, it is important to avoid a Conflict of Commitment. According to University , Conflicts of Commitment relate to an individual university employee鈥檚 distribution of effort between employment obligations to the university and outside professional activities. A Conflict of Commitment arises when time dedicated to professional service, consultation, or research contracted outside the university or other outside activities (e.g., outside teaching or business) interfere with the employee鈥檚 paramount obligations to students, colleagues, and the primary missions of the university. Conflicts of Commitment primarily involve questions of time and effort but are often tied to financial remuneration or other obligations/inducements, and in such cases may also constitute Conflicts of Interest.

1. Tenured and Tenure-Track Faculty.
   The Board of Regents recognizes that full-time tenured and tenure-track baby直播app members are expected to dedicate their professional time and effort to the university.听However, as described in : 鈥渙utside consultation, research, clinical, and other work can serve to keep baby直播app in contact with real problems in their profession and expand their expertise and thus, to the extent authorized by regent laws and policies, are desirable and legitimate functions.鈥� Accordingly, subject to certain conditions (including a commitment to limit outside work to no more than one-sixth of time), the university may allow full-time tenured and tenure-track baby直播app (on both 9-month and 12-month appointments) to obtain approval for outside consultation, research, clinical, and other external professional activities that are related to their professional expertise in their university position. These Faculty should obtain approval using the Application for Approval of Consulting and Other Outside Work Form. See , .
2. Other University Employees.听
   All university employees (including but not limited to research baby直播app) other than tenured or tenure鈥恡rack baby直播app are not permitted to use university time for personal benefit nor for the benefit of external entities, unless approved by the employee鈥檚 Supervising Authority. Supervising Authorities may not authorize such service unless the service advances the interest of the university and does not unduly conflict with the staff member鈥檚 university responsibilities. Moreover, any compensation received for consulting and service on external boards occurring during the staff member鈥檚 normal working hours must be remitted to the university unless the employee is working on authorized vacation or unpaid leave.听Research Associates, PRAs, Research Professors, Lecturers, Teaching Professors and Instructors should obtain approval using the Application for Approval of Consulting and Other Outside Work Form. All other employees should obtain approval using the Authorization to Engage in Outside Employment Form.听See .

For more information, please view the Approval of Consulting and Other Outside Work Guidelines and Procedure document.听

After you submit a DEPA Form, the COIC Office will review the Disclosure to determine if a Conflict of Interest and/or Commitment exists. Disclosure of a Significant Interest(s) that reasonably appears to be related to your Institutional Responsibilities may prompt implementation of a Conflict of Interest and Commitment Management Plan.

The COIC Director will review the Disclosures to determine if any disclosed Significant Interests relate to sponsored or other research. A Significant Interest relates to sponsored or other research when the Significant Interest could be affected by the research or is an entity whose financial interests could be affected by the research. Based on this information, the COIC Director determines whether the Significant Interest could compromise (or appear to compromise) your judgment in exercising any of your university responsibilities, or if the Significant Interest could directly and significantly affect the purpose, design, conduct, or reporting of sponsored or other research.

1. If the COIC Director reasonably determines that the Significant Interest could neither compromise your judgment in exercising your university responsibilities nor directly and significantly affect the purpose, design, conduct, or reporting of sponsored or other research, then no Conflict of Interest exists. If no Conflict exists, you may be required to execute a Management Plan reflecting your commitment to prevent the Significant Interest from ripening into a Conflict of Interest. Your Supervising Authority must approve this Management Plan and the commitments you make. The COIC Office will provide approval notification to you and update your status in its records accordingly.
2. If the COIC Director reasonably determines that the Significant Interest could either compromise your judgment in exercising your university responsibilities or directly and significantly affect the purpose, design, conduct, or reporting of sponsored or other research, then a Conflict of Interest exists. If a Conflict exists, the COIC Office will develop a Management Plan to manage it.

View COIC Review Process

Conflict of Interest or Commitment violations include, but are not limited to:

1. Failure to disclose Conflicts of Interest and/or Commitment;
2. False or inadequate Disclosure of Conflicts of Interest and/or Commitment;
3. Failure to adhere to a prescribed Management Plan; and
4. Failure to adhere to training or reporting requirements.

If the COIC Office determines that an alleged Conflict of Interest or Commitment violation(s) has occurred, the COIC Office will refer the matter to the Supervising Authority for investigation under applicable campus supervisory and/or conduct processes and for potential sanctions. The COIC Office will assist with the matter as requested. In addition, the matter may be referred to other applicable campus units, including, but not limited to: Office of Contracts and Grants, Campus Controller鈥檚 Office, Office of Export Controls, and the Campus Misconduct Advisory Group as necessary in order to protect the university as well as sponsors.

If the alleged violation, including failure of a Discloser to comply with the COIC Policy or a Conflict of Interest Management Plan, appears to have biased the design, conduct, or reporting of sponsored research, the university will comply with any notification and reporting requirements regarding such bias to the applicable sponsor. Specifically, for situations involving PHS-funded research, the university will promptly notify the PHS Awarding Component of the corrective action taken or to be taken.