Each year, members of the faculty are asked to fill out forms detailing outside commitments (employment, consultancies, and other activities) and economic interests. Illinois law and University statutes and regulations require all salaried academic staff to complete an annual Report of Non-University Activities (RNUA). The reporting and approval process is not intended to discourage non-University activities, but rather to ensure that external activities are compatible with University obligations. It is fully recognized that most external activities are consistent with, and often beneficial to, University roles.
These forms must be reviewed first by the unit head who must evaluate whether any stated activity or economic interest may constitute an actual conflict of interest or commitment. In any case where it appears that such a conflict might exist, the executive officer should be in touch with Senior Associate DeanDibyen Majumdar promptly to discuss the activity. University policy requires that faculty be notified of possible conflicts promptly. Unit heads should submit their own forms directly to the dean for the same review. Unit heads should also advise faculty that when a new situation arises in the course of the year, an amendment to the annual report should be filed promptly. The executive officer should review and sign off on Conflict of Interest (COI) forms submitted by staff members.
The academic staff member is required and expected to take the initiative to report promptly and in detail to the unit executive officer, asking for prior written approval for all activities or situations that may involve, or appear to involve, a conflict of commitment or interest, and to respond fully and in a timely manner to inquiries from the unit executive officer in connection with that report.
The unit executive officer has the duty and responsibility to evaluate carefully all potential conflict situations reported or known before acting to approve or disapprove the activities, including teaching at other institutions. As a state institution, the University is entitled to possess sufficient information and control to discharge its obligations of public accountability. Accordingly, in a specific conflict situation, it may be appropriate for the unit executive officer to inquire about a number of factors, including the extent of the time commitment, the income derived by an academic staff member from consulting or management activities, or the extent of financial or other interests in external entities over which the academic staff member or his/her family have sufficient influence to be able to affect its general policy or specific decision.
On each campus, the Vice Chancellor for Research has the responsibility for implementing this Policy. In matters of conflicts of commitment or interest, he/she is advised by a Conflict Review Committee made up of at least three academic staff members. All reports of potential conflicts, remedies for managing them, and sanctions for violation of this Policy shall be transmitted through normal reporting channels to the Vice Chancellor for Research for review and approval. In some cases, final approval by the President or the President's designee may be required. All communications with governmental entities relative to conflicts involving individual academic staff members will be made by the Vice Chancellor for Research.
When a conflict is identified, and a decision is made to allow the activity to proceed, the appropriate University officer may install appropriate monitoring procedures and restrictions to minimize and control the conflict. Mutually agreeable remedies are encouraged. The academic staff member must be afforded an opportunity to respond to a proposed remedy and to appeal it to the next higher administrative level. When an academic staff member violates this Policy or the remedies imposed under this Policy, sanctions may be imposed, subject to appeal.
All parties to the evaluation, management, and approval of conflicts are to make diligent efforts to keep disclosures, remedies, and sanctions confidential to the extent allowed by law. When required by a granting agency, the Vice Chancellor for Research will report a conflict and its management to that agency. Failure to satisfactorily resolve or manage a conflict may require that it be divulged. The granting agency will have access to relevant documents as part of an investigation or audit. The granting agency may also stipulate that significant conflicts of interests must be disclosed at each public presentation of research results.