Policy Number: 410

Policy: Conflict of Interest and Financial Disclosure

Date Adopted: 12/01/2006

Revision Date: 12/97, 12/06, 08/08, 08/12

References: MUS 770, MCA 2-2-1012-2-2022-2-304

Approved By: Royce C. Engstrom, President


I.          INTRODUCTION

The University of Montana-Missoula (UM or University) and its employees are committed to conducting all UM work-related activities in accordance with the highest integrity standards  and in full compliance with all ethical and conflict of interest legal requirements applicable to the University and its employees.  Interactions with the private sector carry an increased conflict of interest risk. This policy sets forth principles for identifying such potential conflicts and procedures for reviewing and addressing potential conflicts that might occur.

II.        POLICY

The University of Montana is committed to fulfilling its mission with integrity and in full compliance with state and federal ethics and conflicts of interest laws and regulations  and with Montana Board of Regents Policy.  A conflict of interest exists when an employee’s professional actions or decisions are or have been influenced by considerations of personal or financial gain.  Therefore, it is the policy of the University that in all of its activities – the education of students; the design, conduct, and reporting of research; the hiring and supervision of staff; the procurement of materials and services; and all other tasks incident to its mission – it shall endeavor to be free of undue influence or bias that may result in conflicts of interest.  This Policy is intended to enable employees to recognize potential conflicting interests and, thus, to protect themselves and the University from such conflicting interests through disclosure, evaluation, and if required, management or elimination of conflicts of interest.

In addition to this Policy, UM employees' ethical conduct is governed by:

III.       APPLICABILITY

This policy applies to all UM employees.  Employees are expected to review and understand their obligations under this Policy and to be familiar with their obligations under the laws, regulations and policies referenced in Section II of this Policy.

IV.       DEFINITIONS

A.        Conflict of Interest.  A Conflict of Interest occurs:

B.        Significant Financial Interest.  A Significant Financial Interest (SFI) consists of one or more of the following interests of the employee (and those of the employee's Immediate Family):

Significant Financial Interests does not include: 

 C.              Immediate Family.  The employee’s spouse or domestic partner and dependent children as determined by the definitions of the Internal Revenue Service and State of Montana laws.

 D.              Investigator.  Principal Investigators, Project Director and all other UM employees who are responsible for the design, conduct, or reporting of sponsored research. 

 E.              Sponsored Research.  Research, creative activities, scholarship, training and instructional projects involving funds, materials, or other compensation from outside sources under agreement.  Research in this context means a systematic investigation designed to develop or contribute to generalizable knowledge, including behavioral and social-science research.

 F.               Responsible Vice President.  The Vice President responsible for the employee’s organizational component of the University, except that in disclosures related to research, the Responsible Vice President shall be the Vice President for Research and Creative Scholarship (VPRCS).

 G.             Investigator's Institutional Responsibilities.  An Investigator's professional responsibilities on behalf of the University, including, but not limited to: research, teaching, service, professional practice, and institutional review board or other institutional committee membership.

Policy Procedures