Conflicts of Interest
The University of Virginia is committed to ethical decision-making, transparency, and stewardship of public trust. This page is designed to help the UVA community find guidance to address potential conflicts between an employee’s personal interests and their University responsibilities.
Depending on the specific circumstances, conflicts of interest are governed by a range of different laws, policies, and departments. Use the sections below to find the guidance most relevant to your situation and/or the offices that are best able to answer your specific questions. Or for general assistance, please contact UVA Compliance at [email protected].
Contractual Conflicts of Interest arise when a UVA employee or family member has a financial interest in a company or organization that seeks to do business with the University. Multiple state laws place restrictions on these situations and may require approval, recusal, or other actions before a contract may proceed.
Examples may include: ownership of a business that provides goods or services to UVA, employment or consulting arrangements with a company seeking a University contract, or financial interests held by a spouse or other family member in a vendor doing business with the University.
Questions? For specific guidance regarding conflicts of interest related to outside contracts with the University, please contact the Office of Financial Compliance at [email protected] or consult the resources below:
- UVA Guidance
- University Policies
Acceptance of gifts, meals, travel, entertainment, or other benefits from vendors and outside organizations may create real or perceived conflicts of interest. State laws and University policies place limits on certain gifts and benefits and, in some circumstances, prohibit their acceptance altogether.
Examples of situations that may raise Conflict of Interest concerns include: a vendor’s offer to pay for travel expenses, provide meals during contract negotiations, or extend gifts to employees involved in purchasing decisions. Employees should consider not only whether a gift is permissible, but also whether accepting it could create the appearance of favoritism or improper influence.
Questions? For specific guidance regarding gifts, gratuities, or vendor relationships, please contact Procurement Services at [email protected] or consult the resources below:
- UVA Guidance
Research investigators must disclose any outside financial interests that could directly affect the design, conduct, or reporting of research. Federal regulations, state law, and University policy require disclosure and review of certain financial interests to help ensure the integrity of research and maintain public trust.
Examples may include: equity ownership in a startup commercializing University research, consulting arrangements with research sponsors, financial interests in companies whose products are being studied, or other relationships that could influence the integrity of research. Additional review may be required when research involves human subjects or when institutional interests could affect research oversight.
Questions? For specific guidance regarding potential conflicts of interest related to research, please contact the Research COI Committee at [email protected] or consult the resources below:
The University recognizes that quality of work can be enhanced when certain employees participate in outside engagements, provided those activities do not interfere with an employee's primary obligations to the University, create real or apparent conflicts of interest, or result in the inappropriate use of University resources.
Examples may include: consulting for a private company, serving on an outside board, holding a second job, campaigning for public office, or engaging in business activities that compete with or overlap with University responsibilities. In some circumstances, prior approval or disclosure may be required.
Questions? For specific guidance regarding outside employment or potential conflicts of commitment, please contact your supervisor or [email protected] (staff) or the Office of the Provost (faculty), or consult the resources below:
- UVA Guidance
- University Policies
- Laws and Regulations
Employees are expected to avoid situations in which family, romantic, or other close personal relationships could appear to influence University decisions. Such situations can create concerns about favoritism, unfair treatment, conflicts of loyalty, or compromised objectivity.
Examples may include: supervising or evaluating a relative, influencing hiring or promotion decisions involving a close personal relationship, or engaging in a romantic relationship in which one individual has academic or employment authority over another.
Questions? For specific guidance regarding nepotism or personal relationships, please contact [email protected] (staff) or the Office of the Provost (faculty), or consult the resources below:
- UVA Guidance
- Laws and Regulations
Any employee designated by the University as serving in a “position of trust” must file a Statement of Economic Interests (SOEI) disclosure directly with the Commonwealth’s Ethics Council, as required by the State and Local Government Conflict of Interests Act. These same employees must also complete the Commonwealth’s Conflict of Interests training within two months of their initial SOEI filing and then biennially thereafter.
Examples of employees serving in positions of trust include: President, Provost, Vice Presidents, and Deans, as well as roles with “substantive authorization and decision-making” in certain areas.
Questions? For specific guidance regarding the Statement of Economic Interests (SOEI), please contact [email protected] or consult the resources below:
Faculty members and other academic personnel may encounter situations in which personal financial interests intersect with teaching, mentoring, publishing, or other academic responsibilities. These situations may create a real or apparent conflict of interest.
Examples may include: assigning course materials from which an instructor receives royalties, directing students to purchase products or services from a faculty-owned company, involving students in businesses from which faculty members benefit financially, or maintaining undisclosed relationships with publishers or vendors. These situations typically become permissible when appropriately disclosed and managed.
Questions? For specific guidance regarding academic conflicts of interest or related matters, please contact your school leadership or the Office of the Provost, or consult the resources below:
- UVA Guidance
- Laws and Regulations
Relationships between health care professionals and industry can create conflicts of interest involving patient care, purchasing decisions, education, and research. Federal health care laws, accreditation standards, and UVA Health policies impose additional requirements beyond those that apply elsewhere in the University.
Examples may include: consulting arrangements with pharmaceutical or medical device companies, industry-funded speaking engagements, gifts or meals provided by industry representatives, participation on advisory boards, formulary decisions, vendor interactions, and industry support for educational activities.
Questions? For specific guidance regarding clinical industry-related conflicts of interest, please contact the UVA Health Corporate Compliance & Privacy Office or consult the resources below:
- UVA Health and Medical Center Policies
Faculty and staff at the University of Virginia's College at Wise are subject to many of the same ethical principles and conflict of interest requirements that apply across the University. In addition, UVA Wise has institution-specific guidance addressing conflicts of interest, outside activities, professional responsibilities, and standards of conduct.
Questions? For specific guidance regarding conflicts of interest at UVA Wise, employees should contact their supervisor or applicable Wise office, or consult the resources below:
- UVA Wise Guidance