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APPENDIX A

The intent of the conflict of interest policy is to foster university activities and outside professional activities as positive contributors to the University of North Dakota. The University sees great value in outside activities that advance and communicate knowledge through interaction with government, industry, the community, and the public, and through consulting and professional opportunities. The conflict of interest policy establishes guidelines to allow faculty and staff at the University of North Dakota to identify potential conflicts, and to manage those conflicts in ways that balance the integrity and interests of the University of North Dakota with those of each University employee.

The conflict of interest forms are designed to identify situations that might lead to conflicts of interest so that they may be properly managed. However, no form is perfect and situations may exist that are not identified by the conflict of interest forms. If you have situations that are not identified by these forms but that may constitute a conflict of interest, please report them to your Executive Head so that they may be properly managed.

It is important to note that it is not the intent here to collect confidential information (e.g., information protected by lawyer-client privilege, doctor-client privilege, a confidentiality agreement, etc.) with these forms. When completing these forms, be mindful that they are subject to the state’s “open records” law.

Instructions for Completing Forms

Annually, all personnel must file with the Executive head of the unit Form 1 (Financial Interests Disclosure Document) and Form 2 (Conflict of Commitment Document). If a potential conflict is indicated on Form 1, then Form 3 (Description of Financial Interest Activity) must be completed for each entity or activity and filed with the Executive head of the unit.

Principal Investigators submitting an external grant proposal must have on file with the Office of the Vice President for Research a current Form 4 (Certification of Filing of Financial Interests Disclosure Document). This form remains valid for a one year period.

If an employee’s status changes during the year regarding potential conflicts of interest, it is the employee’s responsibility to re-file appropriate forms and provide relevant information to Executive Heads to ensure proper conflict of interest management.

The definition of “significant financial interest” is somewhat lengthy and, thus, is provided on the next page for convenience. It is noted that although a specific dollar amount ($10,000) is used for guidance, a conflict of interest can occur for amounts less than this, as indicated in the definition below.

If you have questions regarding the conflict of interest policy, the conflict of interest forms, or conflict of interest in general, please consult with Research Development & Compliance (701-777-4278; 105 Twamley Hall; rdc@mail.und.edu).

Definition of Significant Financial Interest

The term significant financial interest means anything of monetary value, including, but not limited to: salary or other payments for services (e.g., consulting fees, honoraria); equity interests (e.g., stocks, stock options, patents, copyrights, other ownership interests); and non-University royalties from intellectual property rights (e.g., patents, copyrights, trade secrets, and trademarks).

The term does not include: