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Explanation:

An individual or company that has a business or financial relationship with the University also donates a dedicated or undedicated gift.

Examples of Potential Risk Situations:
An individual donor pledges $5 million to a college. A conflict could arise if that individual is being considered for a position or honor granted by that college.

A company pledges $10 million to the University. A potential institutional conflict of interest could arise if the company is also sponsoring research at the University. An actual institutional conflict of interest would arise if the University was encouraged to suppress the research results to keep the gift.

Process for Potential Conflict Identification and Management

1. Identify and disclose the potential conflict
   1. Through reports:

      On a quarterly basis, the Regulatory Affairs Officer compares a list of major donors who pledge $50,000 or more against a database of research sponsors and vendors. If the gift benefits a department or college that also receives research funds from the donor or has a large purchasing contract with the donor, then the research projects or contracts will be put on a list to review.

      Gifts that exceed $5 million annually from a donor who sponsors research in any department or has another type of business or financial relationship at the University will also be added to the list.

   2. Through annual conflict of interest disclosures by department/unit heads and dean:

      Potential conflicts of interest are identified when these employees answer institutional conflict of interest questions on their annual Report of External Professional Activities (REPA) forms (i.e., has your unit or area received a gift from a company that also sponsors research or supplies equipment or services to your unit?).

   3. Through situations reported to University officials by employees or other individuals concerned about possible conflicts of interest.

2. Review the potential conflict

   The Regulatory Affairs Officer will evaluate the risk of an institutional conflict, consulting with individuals and offices involved in the arrangement as necessary.

   • If there is little risk that the donor relationship can affect or appear to affect teaching, research, outreach, or other University activities, the Regulatory Affairs Officer will include the potential conflict in a report that is reviewed by the Board of Regents and the Institutional Conflict Review Committee.
   • If there is a risk that the donor relationship can affect or appear to affect teaching, research, outreach, or other University activities, the Regulatory Affairs Officer will refer the matter to the Institutional Conflict Review Committee.

3. Create a management plan, if needed:

   If a management plan is appropriate, the Institutional Conflict Review Committee will develop it.

4. Determine whether the potential conflict management plan must be approved by the Regents

   The Regulatory Affairs Officer and the Executive Committee of the Institutional Conflict Review Committee will evaluate whether the potential conflict management plan fits the criteria for Regents' approval (it presents an unusually significant financial impact, it involves the president, it raises serious policy issues or has a significant public impact on the University's mission or reputation, or it needs their review under the Reservation and Delegation of Authority policy). If so, the President or delegate will bring the plan to them for review and action. If not, the Regulatory Affairs Officer will summarize the management plan in an annual report to the Regents.

5. Implement the management plan

   Once the Institutional Conflict Review Committee or Regents approve the management plan, the appropriate University official will implement it.

6. Oversight

   The Institutional Conflict Review Committee verifies post-approval compliance with the management plan and addresses any issues that arise.