Conflict of Interest, Conflict of Commitment, Consulting Policy (One-Sixth Rule), and Nepotism in Employment

Conflict of Interest

The University’s original Conflict of Interest Policy was adopted by the Board of Regents on April 26, 1975. The policy addresses two potential types of conflict: interest and commitment.

Conflict of Interest refers to situations in which financial or other personal considerations may compromise, or have the appearance of compromising, an employee’s professional judgment, and may affect the University’s goals related to research, instruction, or administrative programs.

Conflict of Commitment

Conflict of Commitment relates to an employee’s conflict between obligations to the University and those to outside professional activities that promote professional development and enhance contributions to the institution. The University allows full-time faculty to be employed in consultative or research capacities that does not involve more than one-sixth of their time and energy.

Conflicts of Interest and/or Commitment Disclosure

Full disclosure of information and the establishment of a public record are in the best interest of both the institution and the employee. The University requires faculty to submit a Disclosure of External Professional Activities (DEPA) annually. Based upon answers to the DEPA, the Compliance Director for the Conflicts of Interest and Commitment (COIC) Office contacts faculty in need of a “Conflict of Interest MOU.” This MOU includes the type of potential conflict, the nature of the activity, a description of parties involved, etc.

Information regarding conflict of interest with outside business is available at: https://www.cu.edu/policies/aps/hr/5012.pdf. Information on the COIC office and directions on how to access the DEPA form are at: http://www.colorado.edu/VCResearch/integrity/coic/index.html.

One-Sixth Consulting Policy (One-Sixth Rule)

Faculty members may devote not more than one-sixth of their time and energy to outside consulting for which they are paid. One-sixth time is defined as 19.5 days per semester (39 days during the academic year), or one day per week during the regular period of appointment. The One-Sixth Rule applies 24 hours per day, seven days per week during the appointment year. One day of consulting has been defined as being equivalent to 12 hours. Consulting periods that occur in shorter increments than 12 hours may be added together. For example, three-4 hour blocks of consulting may be considered the equivalent of one day of consulting. The time allowed for outside consulting cannot be accumulated from year to year.

A more complete explanation of the One-Sixth Rule and the form for reporting outside consulting activities are available on the web at: https://facultyaffairs.colorado.edu/a-z-information-guide-docs/one-sixth-rule.pdf.

Nepotism in Employment

The Administrative Policy Statement “Nepotism in Employment” states: “University administrators, faculty and staff shall not participate in institutional decisions involving direct benefits such as appointments, retentions, promotions, salaries, leaves of absence, or awards to members of their immediate families… Immediate family members includes spouses, children, parents, grandparents, grandchildren, brothers, sisters, nieces, nephews, uncles, aunts, first cousins, fathers-in-law, mothers-in-law, sisters-in-law, brothers-in-law, sons-in-law, daughters-in-law and any other person who is a member of the employee’s established household.”

When a department chair or program director normally would have a relative or “significant other” reporting to him or her, the Alternate Chair form must be completed and kept on file in the faculty member’s Department and College personnel files.

The College updates its information regarding potential nepotism/relationship conflicts of interest yearly and reports it to the Department of Human Resources, which in turn reports it to the Chancellor.

Personal Conflict of Interest in Cases of Amorous Relationships

A related policy addressing amorous relationships requires that “direct evaluative authority not be exercised in cases where amorous relationships exist or existed within the last seven years.” The responsibility of disclosing the relationship belongs to the person in the evaluative position, and “must be disclosed to the faculty member’s unit head with all parties present…” unless “the individual in the evaluative or supervisory position (is able) to recuse her/himself from exercising further direct supervision of the other party to the relationship, … without stating a reason.” The complete policy is available on the web at: https://www.cu.edu/policies/aps/hr/5015.pdf.