Guidelines for Grant and Contract Management

206. Nonacademic Staff Conflict of Interest

Administrators should note that nonacademic University personnel working on grants and contracts are considered employees of the University of Chicago. Nonacademic employees of the University are subject to the personnel guidelines summarized in the University Personnel Policy Manual and the current employee handbook. – September 2003

In October, 1984, the University promulgated the attached conflict of interest policy for nonacademic personnel. The policy set forth guidelines for all staff members of the University. The policy was developed based upon the belief that it would be useful to reduce to written form some basic guidelines to which staff members can refer in evaluating potential conflict situations. We remain mindful of the fact that good judgment is essential, and that no list of rules or guidelines can provide direction for all of the varied circumstances that arise.

Since the publication of the statement, the Office of Legal Counsel has received inquiries concerning specific situations. It is our view that it would be helpful to set forth at least one area in which advice has been sought and given by the Office of Legal Counsel. That concerns whether it is appropriate for employees doing business on behalf of the University with specific vendors to participate with representatives of those vendors on vacation trips. It is the opinion of the Legal Office that such trips are not appropriate, even when employees pay to the vendor a fee to participate in such trips. Individual vendors will be notified that their sponsorship of such trips is not appropriate. University employees, by this notice, are similarly notified.

It is important that you and the employees in your area carefully review these guidelines. The Legal Office of the University remains available to respond to any questions that you may have concerning this policy or its applicability to specific situations.

Conflict of Interest Policy for Nonacademic Personnel

squares