Conflicts of Interest

UVA employees are subject to a variety of conflict of interest laws, regulations, and requirements. Depending on your official duties for the University and your external financial relationships, you may be asked to disclose a conflict of interest related to three major areas. To seek guidance on specific circumstances, please contact the relevant office directly.

Nature of Conflict	Compliance Regulation	Description	Contact Office
State Filing	State and Local Government Conflict of Interests Act	Statement of Economic Interests (SOEI) disclosure and Conflict of Interest Act training required for positions of trust at the University	UVA Human Resources
Financial	Virginia Public Procurement Act, Ethics in Public Contracting	Employee Disclosure of Conflict of Interest associated with Procurement- or Supplier-related conflicts of interest	Procurement and Supplier Diversity Services
Research	Sponsored Program Requirements	Reporting of financial interests and external professional activities related to research	Vice President for Research

A conflict of interest is defined in University policy as the "real or apparent interference of one person's interest with the interest of another person, where potential bias may occur due to prior or existing personal or professional relationships." From an organizational perspective, this includes situations where a person is in a position to derive personal benefit from actions or decisions made in their official University capacity.

The primary responsibility is on the individual employee to know, understand, and fulfill their personal compliance obligations with regard to conflicts of interest. Note: the same term may not be used consistently throughout the Code of Virginia; for example, “immediate family” is defined differently in the State and Local Government Conflict of Interests Act than it is in the Virginia Public Procurement Act, Ethics in Public Contracting.

University Policies on Conflicts of Interest

Each agency of the University of Virginia has adopted its own policy to addresses potential conflicts of interest. For more detailed information—including clarifications of and links to federal and state laws and regulations—please refer to the policy relevant to your agency:

Academic Division – University Policy FIN-054: Employee Obligation to Report Potential Conflicts of Interest and the University Code of Ethics.
Medical Center – Medical Center Policy 0013: Vendors, Sales and Service Representatives at the Medical Center and Health System Policy BEH-002: Conflict of Interest and Conflict of Commitment
College at Wise – the Faculty Handbook and the Staff Handbook can be found on the UVA Wise Faculty & Staff webpage

This website and the following offices are focused primarily on conflicts of interest in the Academic Division, but you are welcome to contact us for assistance in reaching an appropriate contact elsewhere at the University of Virginia.

Additional Guidance for Specific Areas

Provost – Faculty Conflicts of Interest
School of Medicine – Clinical Research Conflicts of Interest