Conflict of Interest Activities
Examples of allowable activities
The following examples are not considered conflicts of interest:
- Being related to (or having other similar close personal relationship) with someone who attends NAU as a student, so long as you are not a faculty member or instructor, with direct authority, influence, or responsibility for that student.
- Being related to (or having other similar close personal relationship) with another NAU employee, as long as you do not have the ability to influence their employment status through a supervisory or other role (such as being on a search committee for which they are a candidate). Employees who do not supervise each other or have the ability to influence each other’s employment status may work in the same department, but must refrain from having any influence or input on the employment status of the other.
- Having an outside business (unless through the business you provide goods or services to the University), other employment, holding public office, or board membership as long as it does not interfere with your primary commitment to your duties at NAU, and you do not utilize University resources (time, equipment/supplies, facilities, labor, etc.) or your employment with NAU to further your non-NAU activities or personal financial interests. You should refrain from decisions in your role at NAU that are influenced by your outside employment, board memberships, public office, or other similar personal activities. You should also not represent yourself in your other employment, public office, or board membership role as representing NAU.
The following examples are not considered conflicts of interest, unless they are so extensive in time and effort that they constitute a conflict of commitment:
- Receiving salary, royalties, honoraria, stipends, or other remuneration from Northern Arizona University.
- Earning income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities
- Receiving income from service on advisory committees or review panels for public or nonprofit entities.
- Holding financial interests in business enterprises or entities if the value of such interests does not exceed $5,000 per annum of salary, fees, and other continuing payments (or any amount for non-publicly traded entities), or does not represent more than a five percent (5%) ownership interest in any one enterprise or entity; and when aggregated for the Investigator and the Investigator’s spouse and dependent children does not exceed $5,000.
Examples of non-allowable activities
- Failure of the faculty, staff, or administrator to fulfill university responsibilities (e.g., holding classes, advising students, conducting research, serving on departmental or university committees, supervising students in research lab), due to involvement in external activities.
- While acting in the context of his/her university duties, making professional referrals to, or purchasing materials or services from a business in which that staff member or their family member has a financial interest.
- Providing goods or services to the University through your personally owned business without having received a contract resulting from a public competitive bid initiated through the NAU Contracting and Purchasing Services department. Individual departments may not authorize procurements to employee owned businesses.
- Consensual amorous relationships involving a faculty member/instructor and student, or between supervisor and employee, where the faculty member/instructor or supervisor has direct authority, influence, or responsibility with regard to that student or employee are prohibited. Such authority, influence or responsibility includes, but is not limited in the employment setting, to carrying out assignments, evaluations, and promotion or disciplinary decisions. In the instructional setting, such authority includes being responsible for a student’s evaluation and grading, awarding of financial aid or assistantship/employment offers, serving as a member of a student’s thesis or dissertation committee, and the like. These situations tend to interfere or be perceived as interfering with the objectivity of the faculty member’s/instructor’s or supervisor’s decisions with respect to the student or employee. The authoritative position of one party may create an environment that diminishes the freedom of the other to alter or terminate the relationship. Third parties may also be injured by a sexual relationship between two other parties if they are denied privileges that accrue to those who participate in the relationship. Supervisors or faculty members/instructors who engage in such consensual relations are subject to disciplinary action. The scope and extent of such action will be based on the totality of circumstances; these include, but are not limited to, failure to disclose such relationships, failure to remedy such relationships, and repeated violation of this policy. Consensual amorous relationships that violate this policy must be remedied by measures that remove the relationship of authority of the supervisor or faculty member/instructor over the employee or student for all purposes without in any way adversely affecting the status of the subordinate employee or student.
- Employees that are related (or in other similar close relationships) should generally not work in the same department or organization if they are related to a person in the supervisory or management chain. However, in some cases, exceptions are warranted when other reporting arrangements are not possible or practical. Such arrangements must be discussed with a key resource office and a conflict management plan should be documented and monitored.
- Accessing records, data, or information about, or using your NAU role to influence (to the benefit of or detriment of) the NAU student or NAU employment status of a person that is related to you. One must disclose such relationships and refrain from decision-making or influencing decisions about that person.
- Using University resources (time, equipment/supplies, facilities, labor, etc.) or your employment with NAU to further your non-NAU activities, financial or personal interests. NAU employees must refrain from decisions in their role at NAU that are influenced by outside employment, board memberships, public office, or other similar personal activities. NAU employees must also not represent themselves in other employment, public office, or board membership role as representing NAU.
- Using university resources to conduct research that is sponsored by an entity in which the faculty member/researcher or his/her family member has a significant financial interest.
- Serving as a consultant or on the board of directors or major advisory committee of an external for-profit entity which sponsors the faculty member’s/researcher’s research or provides gift funds for the researcher or his/her department.
- Hiring university students in consulting activities or a company in which the faculty member/researcher has financial interests. If the student’s thesis/dissertation research is supervised by the faculty member, the conflict of interest situation may not be manageable.
- Diverting research opportunities from the university to a consulting entity or business in which the faculty/researcher has a financial interest.
- Sponsored projects or technology licensing arrangements in which any of the involved faculty, staff or administrator (or members of their immediate families) have employment or consulting arrangements and significant financial interests in the sponsor, or with subcontractors, vendors, or collaborators.
- Serving as president or CEO, or holding any other position that requires involvement in the day-to-day operations of a for-profit sponsor. Such a situation creates an unacceptable conflict of interest and/or commitment, which must be reduced in order to be manageable.
- Conducting clinical trials on a drug or device developed by the faculty member/researcher IS NOT ALLOWED UNLESS IT DOES NOT involve human research subjects.
- Equity (ownership) interest of the faculty member (or members of the immediate family) in a sponsor.
- Gifts to the university of cash or property which will be under the control, or will directly support the teaching or research activities of a faculty member from an entity in which that faculty member (or members of the immediate family) has an employment or consulting arrangement and/or significant financial interests.