Conflicts of Interest

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.

For example, even if you are not required to file any type of disclosure related to parents and siblings (see the State and Local Government Conflict of Interests Act ) employees still may not participate in any procurement transaction with a firm in which their parents or siblings have a personal and substantial participation in the procurement transaction (see 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:

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