POLICY OWNERS

This policy is jointly owned by the Vice President for Research and the Vice President for University Operations.

PURPOSE OF THIS POLICY

Colorado State University has relationships with a variety of outside entities from which it may benefit, including through gifts, business ventures, royalty payments/equity from licensing intellectual property, as well as by entering into grants, contracts, and other agreements. It is recognized that University–industry relationships are essential for advancing scientific frontiers and enabling the commercial development of academic discoveries to benefit society. This policy is intended to help Colorado State University examine circumstances surrounding the above mentioned activities or other financial relationships tied to education, research, outreach, capital projects, infrastructure facility maintenance, provision of goods and services, athletics, or any other aligned business activity (collectively ‘University Enterprise’), and their nexus with actual or apparent personal gain of Senior Officials and/or the University itself, and manage (through disclosure, oversight, and separation of duties) any actual or apparent conflicts that may affect the integrity and/or public trust in Colorado State University.

APPLICATION OF THIS POLICY

Colorado State University acts through the decisions of its Senior Officials, individuals with administrative authority and autonomy, and capacity to commit University resources. This policy governs the actions of Senior Officials in their individual capacity and as agents of Colorado State University. This policy also governs the actions of Colorado State University as an institution.

STRATA is a private, not-for-profit corporation that is legally separate and independent from Colorado State University. CSU Research Foundation and CSU Foundation are also separate from Colorado State University and are independently governed. Unless specifically addressed in this policy, the actions of STRATA, CSU Research Foundation, and CSU Foundation are sufficiently outside the control of Colorado State University – and its Senior Officials – that no institutional evaluation is necessary.

This policy does not govern circumstances where an individual who is not a Senior Official might realize financial gain either from University decision making or from their performance of other responsibilities at Colorado State University. The Conflict of Interest Committee is charged with reviewing such instances and applies the CSU Policy: Conflict of Interest and procedures to appropriately manage the risks associated with these circumstances.

EXEMPTIONS FROM THIS POLICY

None.

DEFINITIONS USED IN THIS POLICY

Institutional Conflict of Interest: An Institutional Conflict of Interest (ICOI) may occur when the interests of Colorado State University or those of a Senior Official who has authority to act on behalf of Colorado State University, might affect – or reasonably appear to affect – University processes for the purpose, design, conduct, reporting, review, or oversight of research, planning, procurement, or other transaction, or decision involving the University Enterprise or University Core Purpose.

Senior Officials: an individual with the authority and autonomy to commit substantial resources on behalf of Colorado State University. Senior Officials include, but are not limited to, the President, Vice Presidents, Provost, Vice Provosts, and Deans. These Senior Officials have further responsibility to identify other individuals under their supervision who have authority and autonomy to commit substantial resources in their own capacity, particularly individuals who have authority over transactions with outside entities involving the University Enterprise or University Core Purpose.

Covered Transactions: Any transaction or relationship between the University and an outside entity that a Senior Official has the authority and autonomy to enter into in furtherance of their University role. Examples include payments, honoraria, royalties, gifts, equity, options and warrants, membership on an executive board or similar executive-level positions, grants, contracts, benefits, or other consideration.

Significant Financial Interest (individual): For Senior Officials, a “Significant Financial Interest” is consistent with Colorado State University’s governing CSU Policy: Conflict of Interest which is informed by the Code of Federal Regulations 42 CFR 50.603.

Significant Financial Interest (institutional): For the University, a “Significant Financial Interest” occurs when accepting a Covered Transaction from an outside entity is of sufficient magnitude such that it might affect – or reasonably appear to affect – University decision making in a manner that deviates from the University Core Purpose or its objective operation of the University Enterprise.

POLICY STATEMENT

As a public institution with state-, national-, and global reach, Colorado State University has an ever-expanding network of affiliated organizations and avenues to bring the benefits of the University to the broader society. This Institutional Conflict of Interest Policy (ICOI Policy) signals Colorado State University’s commitment to honoring our role in ensuring that the business actions of our Senior Officials are oriented in the best interest of Colorado State University and not for personal gain. Additionally, the ICOI Policy is meant to ensure that the financial holdings of Colorado State University as an institution do not conflict with its adherence to the Mission, Values, and Guiding Principles set forth by the Board of Governors or the Mission, Vision, and Values of the CSU System (collectively, the ‘University Core Purpose’).

POLICY PROVISIONS

Identification of Potential Institutional Conflicts of Interest

The following Significant Financial Interests warrant formal review for potential Institutional COI (ICOI):

Significant Financial Interest (Senior Officials): The following circumstances should be evaluated when Senior Officials are responsible for the direction/control of significant University resources or activities.

• The nature and circumstances of the Covered Transaction;
• The Significant Financial Interests of the Senior Officials involved in decisions regarding the Covered Transaction, and;
• The nexus between the Significant Financial interests and the Covered Transaction.

Significant Financial Interests (Institutional): For the University, acceptance of a Covered Transaction will conform with Colorado State University policy. In addition, the following circumstances will be evaluated:

• The nature and circumstances of the Covered Transaction;
• The alignment of the Covered Transaction with the University Core Purpose and accepted policies and practices that govern the University Enterprise;
• Actual or apparent reputational risk and/or harm to others that may arise from participation in the Covered Transaction.

Although the listed circumstances are potential areas of concern, the goal of the ICOI Policy is not to preclude the University from accepting philanthropy or extramural support. Rather, the ICOI Policy is intended to require the University to develop a means of identifying and examining such circumstances, and of managing, through disclosure, separation of responsibilities, and as otherwise appropriate, mitigate any actual or apparent conflicts of interest that may result through the following guiding principles:

• Institutional financial or business considerations must not be allowed to undermine the objectivity of research, teaching and outreach at the University.
• The numerous and complex relationships between the University and public and private entities require the University to be aware of any relationships that may compromise or appear to compromise its reputation and integrity.

Reservation of Authority

The President, or their designee, has the final authority to select ICOI Committee membership, implement disclosure and review processes, oversee procedures to address ICOI, and to develop and monitor plans for managing, reducing, or eliminating ICOI involving:

• External relationships with an unusually significant financial impact that presents a potential conflict; or
• Potential conflicts that raise serious policy issues or have a significant public impact on the University Core Purpose, University Enterprise, and/or reputation of the University.

In instances where the President may have an ICOI, they must recuse themself and defer to the Board of Governors of Colorado State University who will review, create, and approve management plans in consultation with the Conflict of Interest Office.

Establishment of an Institutional Conflict of Interest Committee

An Institutional Conflict of Interest Committee (ICOI Committee) will be established to review, identify, and manage ICOI. The ICOI Committee will include in its membership an external Senior Official from a peer institution of higher education, the IRB chair, and broad representation from faculty, administrative professionals, and classified staff. Non-voting participants will include a member from the Office of the General Counsel, the co-Chairs of the Conflict of Interest Committee, and a representative from each of the CSU Research Foundation, CSU Foundation, and STRATA. The ICOI Committee will be advisory to the President, who holds final authority regarding questions of ICOIs, and submit to them an annual report.

Disclosure

Senior Officials covered under the ICOI Policy shall, upon appointment, annually thereafter, and within 30 days of acquiring a new Significant Financial Interest, file a Financial Disclosure Statement (see Appendix II) with the Office of the President disclosing Significant Financial Interests (including those of a spouse, dependent children, or immediate family members).

Disclosure to IRB

Senior Officials covered under the ICOI Policy shall disclose to the Colorado State University Institutional Review Board any Management Plans issued under this policy, with regard to their Human Subjects research activities reviewed by the IRB.

Notification of Changes in Significant Financial Interest

Senior Officials and other individuals covered under this policy shall provide the ICOI Committee with a revised Financial Disclosure Statement within 30 days of acquiring any new Significant Financial Interests.

COMPLIANCE WITH THIS POLICY

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

REFERENCES 

Code of Federal Regulations 42 CFR 50.603

CSU Policy: Conflict of Interest

FORMS AND TOOLS

Conflict of Interest

APPROVALS

Effective July 16, 2025