POLICY OWNERS

This policy is jointly owned by the Office of the Provost/Executive Vice President and the Vice President for Research.

PURPOSE OF THIS POLICY

The University recognizes that Reportable Outside Activities can provide valuable opportunities for Employees to grow their professional expertise, serve a public good, and expand professional networks. The University encourages such activities when they are consistent with the University’s mission.

Notwithstanding, an Employee’s primary professional Commitment of time and intellectual energy must remain with the University, and Reportable Outside Activities must not interfere with an Employee’s ability to fulfill University responsibilities, including satisfying Commitments to sponsored projects.

This Policy establishes the University’s process for the disclosure, review, management, monitoring, and reporting of Conflicts of Commitment.  The Conflict of Interest Office is the University’s designated office responsible for the administration, review, management, monitoring, reporting, and enforcement of this Policy and associated procedures.

APPLICATION OF THIS POLICY

This policy applies to any Employee and other individual designated by the University as subject to this Policy based on their role, responsibilities, or participation in University activities.

EXEMPTIONS FROM THIS POLICY

Students and Student Interns are generally excluded from this Policy unless they participate in certain federally sponsored projects, hold positions that require disclosure under University Policy or sponsor requirements, or are otherwise directed by the University to complete a Conflict of Interest and/or Conflict of Commitment Disclosure.

DEFINITIONS USED IN THIS POLICY

Commitment: Any obligation of time, effort, service, appointment, affiliation, employment, fiduciary responsibility, research activity, or other undertaking owed to an entity other than Colorado State University, whether compensated or uncompensated.

Conflict of Commitment (COC): A situation in which an individual accepts or incurs conflicting obligations between or among the University and one or more external entities, whether domestic or foreign, that may interfere with their ability to fulfill University responsibilities, devote appropriate time and effort to University activities, or comply with sponsored project Commitments.

Employee: An Employee of Colorado State University (CSU), including but not limited to all Academic Faculty, Affiliate Faculty, Emeritus Faculty, Administrative Professionals, State Classified, post-doctoral Fellows, Professional Interns, and Non-Student Hourly Employees, including those on leave of absence with or without pay.

Procedures: Establish the University's requirements for disclosing, reviewing, managing, monitoring, reporting, and overseeing interests, activities, relationships, and Commitments that may create actual, potential, or perceived conflicts. They can be found linked in the Forms and Tools section below.

Reportable Outside Activity: A Commitment that must be disclosed under this Policy and associated University procedures.

University: Any University housed under the CSU System.

University Responsibilities: An Employee's professional duties and obligations on behalf of the University, including but not limited to teaching, research, service, clinical activities, veterinary activities, administration, procurement, technology transfer, student advising and supervision, outreach, and other assigned institutional responsibilities.

University Resources: University-owned, leased, licensed, or controlled assets and resources, including facilities, equipment, funds, information technology systems, intellectual property, non-public information, personnel time, services, supplies, official titles, institutional affiliations, and other resources provided to support University activities.

POLICY STATEMENT

Employees are expected to devote their professional and intellectual efforts primarily to fulfilling their responsibilities to the University. Reportable Outside Activities are permitted when they support professional development, public service, or innovation and do not interfere with University duties. Employees must ensure that Reportable Outside Activities do not diminish the quality, quantity, or availability of effort dedicated to University Responsibilities. Use of University Resources, personnel, facilities, or non-public information for Reportable Outside Activities is prohibited unless specifically authorized.

Employees must accurately disclose Reportable Outside Activities. Employees must update disclosures at intervals established by University procedures and whenever material changes occur in previously disclosed activities. When a Conflict of Commitment is identified, the University may require strategies to manage, mitigate, or eliminate the conflict. Failure to disclose Reportable Outside Activities or comply with approved management strategies may result in corrective action.

Researchers must additionally comply with all applicable sponsor requirements governing outside activities, including any additional disclosure, management, reporting, or compliance obligations established by law, regulation, award terms, and agency policies.

POLICY PROVISIONS

Reportable Outside Activities are disclosed, reviewed, and addressed consistent with written University procedure.

Certain Reportable Outside Activities identified by University procedures may require advance review and approval before the Employee may participate in the activity. Participation in a Malign Foreign Talent Recruitment Program is strictly prohibited, consistent with University policy.

Approval to engage in a Reportable Outside Activity does not alter or diminish the Employee’s duties or responsibilities to the University.

COMPLIANCE WITH THIS POLICY

Compliance with this policy is required.

Employees may be subject to corrective or disciplinary action, consistent with applicable University policies and procedures, if they:

• Fail to disclose a Reportable Outside Activity as required by this Policy.
• Submit incomplete, inaccurate, misleading, or false information in connection with a disclosure or review.
• Fail to timely update required disclosures.
• Fail to comply with terms and conditions of a Conflict of Commitment Management Plan.
• Fail to cooperate with a review, monitoring activity, or request for information related to a disclosed activity.
• Otherwise violate this Policy or associated procedures.

The University may conduct reviews, require corrective actions, modify or terminate management plans, and make sponsor notification when required by law, regulation, award terms, or University policy.

For assistance with interpretation or application of this policy, contact the Conflict of Interest Office.

REFERENCES

CSU Policy: Conflict of Interest
CSU Policy: Effort Reporting
CSU Policy: Prohibition on Participation in Malign Foreign Talent Recruitment Programs (7-2001-20)
CSU Policy: Financial Conflicts of Interest in Federally Funded Programs
CSU System Policy: Acceptable Use Policy
C.R.S. § 24-18-103 — Public Trust – breach of fiduciary duty
C.R.S. § 24-18-104 — Rules of Conduct for Public Officers and Employees
C.R.S. § 24-18-105 — Ethical Principles for Public Officers, Local Government Officials, and Employees
C.R.S. § 24-18-201 — Interests in Contracts
C.R.S. § 24-50-117 — Prohibited Activities of State Employees
2 CFR 910 Financial Assistance Regulations—Conflict of Interest and Conflict of Commitment Policy Requirements (Department of Energy)

FORMS AND TOOLS

Outside Activity Report (located within Kuali COI module)
Effort Certification Training
Procedures: Conflict of Interest and Conflict of Commitment (Under Development)
Research Integrity, Security & Compliance – Conflict of Interest Office

APPROVALS

Effective June 23, 2010

Revision approved on June 21, 2011

Revision approved by Brendan Hanlon, Vice President for University Operations, on August 13, 2026