Understanding COI

Best Practices

The following is intended to set appropriate bounds for outside activities that are deemed not to create a financial conflict of interest or require a formal management plan. Consult with the UNCG COI Official (coi@uncg.edu or 336-256-1173) if you require an exception to any of the following best practices.

Consulting

  • Do not agree to a consulting relationship with an entity that that creates a conflict with your responsibilities to the university as your primary employer.
    • Typically, this takes the form of a conflict of commitment with respect to time and effort already committed to the university.
    • External activities for pay should generally not exceed 20% of one’s contract time.
  • Do not enter into relationships that limit publication, without receiving approval from the university.
  • Do not imply university approval or support of outside activities without express permission from an authorized university representative. However, you may identify yourself as a university employee.
  • Do not use university resources to benefit a personal consulting relationship without permission and fair compensation.
  • Do not involve students or use university staff to support consulting activities.
  • Do not sign agreements that assign university patent and other intellectual property rights to a third party without prior university approval.
    • Consulting agreements which include intellectual property provisions should be reviewed by the Office of Technology Transfer to ensure that the agreement does not conflict with applicable University policies on intellectual property.
  • Do not sign an agreement that could limit future sponsored research activities at the university. Before signing a consulting agreement, look out for the following provisions:
    1. Assignment of university intellectual property to the outside entity engaging you as a consultant
    2. Non-compete agreements or other restrictions on research funding sources
    3. Publication restrictions

Start-up or other company ownership

  • Approval required for external activities, and time commitment should be limited to no more than one day per week for all outside activities.
  • State law prohibits self-dealing (NC GS 14-234), meaning that, as a state employee, you may not participate in making or administering a contract in which you or your spouse will directly benefit.
    • Company cannot sponsor University research in your lab.
    • You may not subcontract to your company.
  • Disclose personal ownership or financial interests in companies doing business with the university. This includes clients of a start-up that sponsor your University research.
  • Disclose and recuse yourself from involvement in University financial or contractual transactions with any company in which family members have ownership positions or financial interests.
  • Separate and clearly distinguish University research from company activities.
  • External professional activities, including managing a company, should generally not exceed 20% of one’s contract time.
  • Step-down from a management role as soon as reasonably possible.
  • Do not negotiate with University on behalf of the company
  • Do not involve your current students in the company
  • Do not make use of University services and personnel, unless available to the general public.
  • Do not use University facilities or equipment for company purposes without an appropriate agreement in place.

SBIR/STTR considerations:

  • PI restriction: No person can request funds (or financially benefit) through more than one institution for a single NSF SBIR/STTR project.
  • Subcontracting: No person who is an equity holder, employee, or officer of the proposing small business may be paid through a subaward budget unless an exception is recommended by the Program Director and approved by the Division Director for the Division of Industrial Innovation and Partnerships.
  • Consulting: No person who is an equity holder, employee, or officer of the proposing small business may be paid as a consultant unless an exception is recommended by the Program Director and approved by the Division Director for the Division of Industrial Innovation and Partnerships.

Source: UNC Charlotte’s Conflict of Interest Manager

 

COI primary contact


Lisa A. Goble, PhD
Director, Office of Research Integrity
Phone: 336.256.1173
lagoble@uncg.edu