EFFECTIVE DATE: November 30, 2021
ISSUE #: 2
PRESIDENT: Dr. Loren J. Blanchard
This PS outlines the standards of procedure and conduct in Government-sponsored
research adhered to by the University of Houston-Downtown (UHD). These standards
are part of a joint statement of The Council of the American Association of University
Professors and The American Council on Education. All University employees must
abide by the procedures outlined herein to prevent conflicts of interest with outside
parties, including government agencies.
There are no definitions for this policy.
3.1 Favoring of Outside Interests and Conflicts of Interest are covered more thoroughly
in UH SAM 02.A.09, UHD PS 05.A.07, and UHD PS 06.A.09. When a University
employee involved in government- sponsored work has a significant financial
interest in, or a consulting arrangement with, a private business concern, actual or
apparent conflicts of interest must be avoided between his/her government-sponsored University research obligations and his/her outside interests and other
obligations. Situations in or from which conflicts of interest may arise are:
3.1.1 Undertaking or orientation of the employee’s University research to serve
the research or other needs of the private firm without disclosure of these
activities to the University and to the sponsoring agency;
3.1.2 Purchase of major equipment, instruments, materials, or other items for
University research from the private firm in which the employee has the
interest without disclosure of such interest;
3.1.3 Use for personal gain or to benefit a private entity of Government-sponsored work products, results, materials, records, or information that
are not made generally available (This would not necessarily preclude
appropriate licensing arrangements for inventions, or consulting on the
basis of Government- sponsored research results where there is significant additional work by the employee independent of the Government-sponsored research);
3.1.4 Use for personal interest or other unauthorized use of privileged
information acquired in connection with the employee’s Government-sponsored activities.
Privileged information includes, but is not limited to, medical, personnel
or security records of individuals; anticipated material requirements of price
actions; possible new sites for government operations; and knowledge of
forthcoming programs or selection of contractors/subcontractors in advance
of official notice.
3.1.5 Negotiation or influence upon the negotiation of contracts relating to the
employee’s Government-sponsored research between the University and
private organizations with which the employee has consulting or other
3.1.6 Acceptance of gratuities or special favors from private organizations
with which the University does or may conduct business in connection
with a Government-sponsored research project, or extension of gratuities
or special favors to employees of the sponsoring Government agency,
under circumstances which might reasonably be interpreted as an attempt to
influence the recipients in the conduct of their duties.
3.2 Distribution of Effort is covered more thoroughly in UHD PS 06.A.06 and UHD PS
06.A.07. There should be a clear understanding, by all concerned parties, of the amount of
time and responsibilities for which an employee is accountable, when involved in
Government-sponsored research. A demonstrable relationship between the effort or
responsibility proposed in the research agreement and the actual extent of the employee’s
involvement is expected in order to avoid any misconceptions of the amount of
intellectual effort being devoted to the research in question.
3.3 Consulting for Government Agencies or their Contractors. When the University employee
engaged in Government-sponsored research also serves as a consultant to a Federal
agency, his/her conduct is subject to the provisions of the Conflict of Interest Statutes (18
U.S.C. 202-209 as amended). If the employee consults for one or more Government
contractors, or prospective contractors, in the same technical field as his/her research
project, care must be taken to avoid giving advice that may be of questionable
objectivity because of its possible bearing on his/her other interests. In undertaking and
performing consulting services, the employee shall make full disclosure of such interests
to the University and to the contractor insofar as they may appear to relate to the work at
the University for the contractor.
3.4 University Responsibilities. UHD recognizes that disclosure and consultation are the
obligations assumed by the University when it accepts government funds for research.
UHD will herein implement organizational and administrative actions to prevent conflicts
of interest in Government-sponsored research.
3.4.1 The Associate Vice President for Faculty, Research, and Sponsored Programs
and the Principal Investigator will insure that all Government funds are
expended for the purposes for which they are intended and that all services
which are required in return for these funds are supplied.
3.4.2 Any UHD employee involved in Government-sponsored research must consult
with the appropriate vice president before accepting any outside professional
work to insure there will not be any real or perceived conflicts of interest with
3.4.3 The AVP-ORSP or designee will serve as an informed source of advice and
guidance for consultation on problems that may or do develop as a result of
University employees’ outside financial or consulting interests, as they relate to
their participation in any Government-sponsored research.
3.4.4 All University employees participating in Government-sponsored research
must abide by the standards outlined herein as well as those delineated in all
Grant Administration policies (PS 06.A.xx).
4.1 Any UHD employee involved in government-sponsored research must consult with the
appropriate vice president before accepting any outside professional work to insure
there will not be any real or perceived conflicts of interest with the research.
4.2 The AVP-ORSP or designee will serve as an informed source of advice and guidance
for consultation on problems that may or do develop as a result of University
employees’ outside financial or consulting interests, as they relate to their participation
in any Government-sponsored research.
4.3 All University employees participating in government-sponsored research must abide
by the standards outlined herein as well as those delineated in all Grant Administration
policies (PS 06.A.06).
Responsible Party (Reviewer): Associate Vice President for Faculty, Research, and
Review: Every three years on or before May 1st.
Signed original on file in Employment Services and Operations.
Issue #1: 05/02/01
There are no references for this policy