Policy Library - Office of Policy & Compliance

Policy Title: Interim Conflict of Interest	Category: Research
Owner: Vice President for Research	Policy ID#: 1-1001-004
Contact: Conflict of Interest office Web: https://www.research.colostate.edu/safety-and-compliance/conflict-of-interest/ Email: vpr_office@colostate.edu	Original Effective Date: 6/23/2010 Last Revision: 8/13/2026
	*Print Version: Click Here to Print*

PURPOSE OF THIS POLICY

The University encourages Employees to participate in professional, scholarly, civic, entrepreneurial, and community activities that advance the University's mission and serve the public good. Notwithstanding, the University is committed to maintaining the highest standards of integrity, objectivity, accountability, and public trust across all aspects of its mission, including teaching, research, service, administration, procurement, business operations, and other University activities.

Employees are therefore expected to perform their University Responsibilities in a manner that preserves public trust, supports institutional integrity, and promotes objective and impartial decision-making. Personal, financial, professional, business, familial, or other external interests must not improperly influence, or reasonably appear to influence, University decisions or activities.

This Policy establishes the University's process for identifying, disclosing, reviewing, managing, monitoring, and reporting Outside Activities and Interests. The Conflict of Interest Office is the University's designated office responsible for administration and enforcement of this Policy and its associated procedures.

APPLICATION OF THIS POLICY

This Policy applies to all Employees, of the University.

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 Outside Activities 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 Interest: A situation in which an Employee's personal, financial, professional, business, familial, or other external interests, or the interests of a Related Party, could directly or indirectly affect, compromise, or reasonably appear to affect the Employee's objectivity, professional judgment, decision-making, or actions in carrying out University Responsibilities.

Employee: An Employee of Colorado State University regardless of appointment type, funding source, compensation arrangement, or employment classification, including but not limited to all 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.

Financial Interest: Any economic interest held by an Employee or a Related Party, whether direct or indirect, including but not limited to compensation, consulting income, honoraria, equity interests, ownership interests, stock options, intellectual property rights, royalties, licenses, gifts, loans, sponsored or reimbursed travel, fiduciary positions, or other financial benefits.

Perceived Conflict: A situation in which a reasonable person, possessing the relevant facts, could conclude that an Employee's personal interests may improperly influence the performance of University Responsibilities, regardless of whether an actual conflict exists.

Procedures: The Procedures: Conflict of Interest and Conflict of Commitment 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 its associated Procedures.

Related Party: An individual's spouse, domestic partner, dependent child, parent, sibling, household member, or any other person or entity whose relationship with the Employee could reasonably be expected to create, contribute to, or appear to create a Conflict of Interest.

University: any University housed under the Colorado State University 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 shall not allow personal, financial, professional, business, familial, or other external interests, including the interest of a Related Party, to improperly influence, or reasonably appear to influence, the performance of their University Responsibilities.

Employees shall not use University or State resources, property, facilities, information, equipment, personnel, services, funds, or their University position or authority for personal gain, a Related Party, or an external individual or entity, except as authorized by University policy or with prior written approval from the appropriate University authority.

Employees must accurately disclose Financial Interests, Reportable Outside Activities, and other relationships that may create an actual, potential, or Perceived Conflict of Interest in accordance with this Policy and its associated Procedures. Employees must provide complete and accurate information, cooperate with requests for additional information, and update disclosures at intervals established by the Procedures and whenever material changes occur in previously disclosed information.

When an actual, potential, or Perceived Conflict of Interest is identified, the University may require measures to manage, mitigate, reduce, or eliminate the conflict. Failure to disclose required information or comply with approved management measures may result in corrective action.

POLICY PROVISIONS

Reportable Outside Activities, Financial Interests, and other relationships subject to disclosure requirements are disclosed, reviewed, and addressed consistent with the Procedures.

When an actual, potential, or Perceived Conflict of Interest is identified, the University may require implementation of a Conflict of Interest Management Plan or other measures to manage, mitigate, reduce, or eliminate the conflict.

Certain activities identified in the Procedures may require advance review and approval before an Employee may participate in the activity. Participation in a Malign Foreign Talent Recruitment Program is strictly prohibited, consistent with University policy.

Approval of an activity or Financial Interest does not alter or diminish an Employee's responsibilities to the University or relieve the Employee of ongoing disclosure, management, monitoring, or compliance obligations.

Researchers funded by federal sponsored programs may additionally be subject to the University's Financial Conflict of Interest (FCOI) Policy and applicable sponsor requirements.

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 Interest Management Plan.
Fail to comply with terms and conditions of an approved Conflict of Commitment Management Plan, when applicable.
Fail to cooperate with a review, monitoring activity, or request for information related to a disclosed activity.
Otherwise violate this Policy or its 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.