Conflicts of Interest
UC Regents Policy 1111
Employee members of the University community are expected to devote primary professional allegiance to the University and to the mission of teaching, research and public service. Outside employment must not interfere with University duties. Outside professional activities, personal financial interests, or acceptance of benefits from third parties can create actual or perceived conflicts between the University's mission and an individual's private interests. University community members who have certain professional or financial interests are expected to disclose them in compliance with applicable conflict of interest/conflict of commitment policies. In all matters, community members are expected to take appropriate steps, including consultation if issues are unclear, to avoid both conflicts of interest and the appearance of such conflicts.
Managing Conflicts of Interest
UCR's Chief Compliance Office supports UCR's efforts to prevent and manage conflicts of interest and conflicts of commitment by:
- increasing awareness (education) of policies and resources
- investigating certain reported conflicts of interest policy violations and
- managing the Form 700 Statement filing process.
What is a Form 700?
Certain UCR employees, called "Designated Officials", are required to complete Statements of Economic Interests (Form 700). A Designated Official holds a position which the University or the California Fair Political Practices Commission (FPPC) has identified as having the potential for decision-making which could give rise to a financial conflict of interest. In addition to being subject to the Act's disqualification requirements, a designated official must file, as public documents, financial disclosure statements upon assuming or leaving a designated position and annually while holding the position.
Designated Officials are required to file Form 700s annually (no later than April 1) and within 30 days after assuming office (being hired, nominated, or appointed). They must also file a Statement within 30 days of leaving the university. Form 700s are available for public review on the FPPC website.
Form 700 Statements of Economic Interests must disclose certain:
- interests in real property;
- income; and
- business positions.
The UC Office of the President provides online resources and guidance on how to file the Form 700. The California Fair Political Practices Commission also provides information and tutorials on filing Form 700s on its website at http://www.fppc.ca.gov/Form700.html .
There is also specific guidance on the Limitations and Restrictions on Gifts, Honoraria, Travel, and Loans for designated filers and on Leaving the University -- Post-Employment and Revolving Door Guidance.
Failure to file a Statement timely will result in referral to the FPPC Enforcement Division and a penalty of up to $5,000 may be imposed. See the Late Filing Guidelines for more information.
UC Conflict of Interest Code
The UC Conflict of Interest Code details the designated positions that shall file Statements of Economic Interest (Form 700). In the Code, each designated position is also assigned to one or more disclosure categories and must disclose reportable financial interests in each category assigned.
The relevant disclosure categories for designated employees are as follows:
- All interests in real property, all investments, all income, including gifts, loans and travel payments, and business positions.
- Interests in real property located within two miles of the laboratory or campus at which the designated employee works, or within two miles of land owned or used, or proposed for acquisition or use by such laboratory or campus.
- Investments and business positions in business entities and income, including gifts, loans, and travel payments, from sources of the type which, within the last two calendar years, have contracted with the University to (a) supply goods or services to, and/or (b) receive licenses in existing patents, patent applications, and rights in patents and patent applications from, the University, campus, laboratory, or portion thereof (including but not limited to, department, section, or office) over which the designated employee has authority relevant to these contracts. Services include providing grant, contract, or gift funds for research.
- Interests in real property located within the State of California.
- Investments and business positions in business entities and income, including gifts, loans and travel payments, from sources of the type which, within the last two calendar years, have contracted with the University to supply goods or services (including providing grant, contract, or gift funds for research) to the unit(s) for which the designated employee has authority relevant to these contracts.
If you need further information about whether you are a designated employee or about your disclosure categories, please reach out the UCR Conflict of Interest Coordinator, Ian Harazduk at email@example.com or (951) 827-8246.
The disclosure category (or categories) determine the schedules that are required to be completed on the Form 700. For example, if your disclosure category does not require you to report interest in real property, then you would not need to complete Schedule B – Real Property.
All schedules on the Form 700 and a listing of common reportable and non-reportable interests is noted below and can be found on the FPPC Form 700 Quick Start Guide:
Note: Designated employees need not report any investment in a business entity or real property worth less than $2,000 or any source of income, including gifts, loans and travel payments, which aggregated is less than $500 (if a gift, less than $50) during the reporting period.
Conflicts of Interest in Research
The Office of Research Integrity, part of UCR's Research and Economic Development division, provides broad oversight, resources and education for integrity and compliance issues relating to the conduct of research at UCR. The office also helps prevent and manage financial conflicts of interest arising in the context of research activities.
Visit ORI's website on the Promoting Research Objectivity (PRO) Committee to learn about COI management and for information about reporting (disclosure) forms 700-U (California form), 500 (Public Health Service rules), and 925 (National Science Foundation).
Conflicts of Commitment
Conflicts of commitment arise when a UCR's employee has outside (non-UC) employment or professional activities that may compete or interfere with their primary duty to UCR.
Regents Policy 7303 sets forth the service obligation owed by all UCR officers, faculty, and staff that no compensation shall be paid to any office, faculty member, or employee unless actively engaged in the service of the University and that no one in the service of the University shall devote to private purposes any portion of time due to the University nor shall outside employment interfere with the performance of University duties.
Regents Policy 7707 sets forth the specific guidelines for Senior Management Officials who undertake paid or un-paid obligations outside their roles for the University.
APM-025 sets forth specific guidelines that faculty must adhere to in undertaking outside professional activities. Faculty conflicts of commitment are managed by UCR's Office of Academic Personnel. Certain outside employment or professional activities must be disclosed and approved in advance. and/or must be reported annually. Different rules apply for faculty covered by the Health Sciences compensation plan. For more information on the matter, see the Vice Provost's communication on conflict of commitment, FAQs on conflict of commitment, or visit the APO website.
PPSM-82, Section II.B. sets forth the standards relating to outside professional activities that are applicable to University staff.