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PS-06.A.03 - Standards of Conduct in Government Sponsored Research

​​​EFFECTIVE ​DATE: November 30, 2021

ISSUE #: 2

PRESIDENT:​  Dr. Loren J. Blanchard

PURPOSE

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.

DEFINITIONS

There are no definitions for this policy.

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 significant influence. 

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 the research. 

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).

PROCEDURES

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).

REVIEW PROCESS

Responsible Party (Reviewer): Associate Vice President for Faculty, Research, and Sponsored Programs

Review: Every three years on or before May 1st.

Signed original on file in Employment Services and Operations.

POLICY HISTORY

Issue #1: 05/02/01

REFERENCES

There are no references for this policy​​

Last updated 3/7/2022 1:55 PM