Who is subject to this policy?
The policy requires university employees, whether faculty, Officers of Administration, or classified staff, to use the university disclosure process.
I submitted a Significant Financial Interest (SFI) declaration for my sponsored research. Aren’t I covered?
No. This is a separate disclosure, required for different reasons. The SFI declaration is required by federal regulation and is used to determine whether you have a financial conflict of interest (FCOI) with any of your sponsored research. This disclosure is broader than that and relates to state law and requirements related to your employment. The reporting system under development is intended to allow for a one-stop disclosure process.
Does this policy apply to only newly acquired equity ownership and outside activities going forward, or do I have to disclose equity ownership or activities from the past?
If you are currently engaged in something that is described above as requiring prior approval, you should disclose it at this time.
How often do I need to disclose?
Disclosures are required whenever there is a change to your circumstance that needs review or approval, and once an item disclosed – even if it doesn’t change – it will be reviewed annually.
My supervisor already knows what I am doing outside of work and is fine with it. Do I still need to disclose anything through this process?
Yes, you should still disclose through this process. When describing your financial interest or outside activity, include information about any prior disclosures you have made and what, if any, arrangements were made to ensure the interest or activity does not create a conflict.
How long does the process take?
The process will vary based on each individual situation. We will provide you an estimate once we know more about your inquiry. An estimate may change (shorter or longer) dependent on the type and timing of the information we receive from you and your department/unit and college/division.
What is an Institutional Management Plan?
An IMP is something agreed upon by the employee, the employee’s supervisor(s), and the president’s designee to approve such plan (currently this is the Sr. Associate Vice President for Research and Innovation). The plan helps to develop a record and to ensure everyone is on the same page about how any conflicts, or potential conflicts, will be managed.
Do I have any say in what goes into the Institutional Management Plan?
Yes. Staff charged with the disclosure review process and development of the management plan will work closely with the employee, their supervisor, and relevant leadership to explore all options for managing conflicts, and to ensure an appropriate outcome to manage any actual or potential conflicts.
Are employee disclosures and management plans made public?
Disclosures of actual and potential conflicts are not posted publicly. Disclosures of actual and potential conflicts, and their associated Institutional Management Plans, may be subject to disclosure under a public records request. The public records office would review for any information in a disclosure or an IMP that should be made public or that should be redacted under public records laws.
I have concerns about another UO employee’s outside activity; where or how can I report those concerns.
If you have a concern about another employee’s activities, please visit the UO’s centralized “Report a Concern” webpage.