Conflicts of Interest and Outside Activities Reporting
The UW System encourages faculty and staff to engage in all types of activities that further their personal and professional goals and that make the System a better place to work, learn, and thrive. When you engage in activities outside of your typical job duties as an employee of the UW System, it is important to avoid pursuits that could conflict with your public responsibilities to the UW System. All University of Wisconsin System employees are required to comply with the code of ethics applicable to their employment type.
All UW System staff are required to report conflicts of interest
Faculty, Academic Staff, and Limited Appointees with half-time appointments or more are required to report annually outside activities and interests related to their areas of professional responsibility and for which they receive remuneration by April 30 of each year under the Wisconsin Administrative Code, Chapter UWS 8. Any faculty, academic staff and limited appointee employee who are also “contracting personnel” per UWS 8.06 may be required to file a Statement of Economic Interest (SEI) report with the Wisconsin State Ethics Commission (see section below for more information).
University Staff are governed by Regent Policy Document 20-22, Code of Ethics. When it appears that a material conflict may arise between the personal interests of a University Staff member and their public responsibilities, the University Staff member shall notify their supervisor or other appropriate administrators by submitting a written statement describing the nature of the possible conflict. Note that university staff who are also defined as “contracting personnel” per UWS 8.06 may be required to file a Statement of Economic Interest (SEI) report with the Wisconsin State Ethics Commission (See section below on Contracting Personnel for more information).
Managers and Supervisors are responsible for reviewing the information provided by employees that may identify conflicts of interest and providing guidance on how to proceed. Any time a supervisor is made aware of a potential conflict of interest, whether through receipt of an Outside Activities Report or through another means, the supervisor should meet with the employee to discuss and determine whether a potential conflict may exist. See Supervisors and Managers: Review Process below for more information.
Contracting Personnel are also required to file a Statement of Economics Interest (SEI) with the Wisconsin State Ethics Commission, per UWS 8.06. This includes any person who has been delegated signature authority from its institution, which may include faculty, academic staff, university staff or limited appointees. “Contracting Personnel” are defined as persons who are designated in writing by the chancellor of an institution or the president of the system to negotiate, review, approve, or sign contracts for the purchase of goods and services on behalf of an institution, the university system, or the board. The term does not include persons who do either or both of the following: (a) contract only with outside agencies for research or for services to be performed by the university; or (b) negotiate, review, approve or sign only employment contracts. To determine whether you are defined as “contracting personnel” for purposes of this reporting requirement, please contact your institution’s Office of Human Resources.
All Staff should annually review Regent Policy Document 13-4 on Institutional and Employee Relationships with Educational Loan Lenders.
Faculty, Academic Staff, and Limited Appointees
It is the policy of the University of Wisconsin System to require a report from all faculty, academic staff and limited appointees who engage in remunerative outside activities in their field of professional interest whose appointments are half-time or more for the period under contract to the UW System. If you have a joint appointment, you must file a report for each department/unit. Your report covers activities that occur during the full year, even if you were not under contract to the University for part of that time. You should discuss with your dean or director any activities that may present carryover questions of conflict with your responsibilities during your contract period. Additionally, while the form gathers information for the prior year, staff are required to report any changes in your circumstances as they occur as soon as possible.
Note: The President, Chancellor or his/her designee may provide exception to the deadline of completing this form in extenuating circumstances. Notwithstanding the exception, the employee must immediately submit this form upon his/her return to work.
Faculty, Academic Staff and Limited Appointees use the Outside Activities Report form to report:
A remunerative relationship which is any relationship that results in payments, transfer of goods or provision of services to the reporting staff member.
An organization is any corporation, partnership, proprietorship, firm, enterprise, franchise, association, trust or the legal entity other than an individual or body politic (see Wis. Admin. Code § UWS 8.02(12).
Professionally related activities are activities related to the staff members’ field of academic interest or specialization.
Ordinary professional activities are those activities which extend an unclassified staff member’s normal institutional responsibilities of teaching, research and service to serving other public institutions, organizations, and professional societies. Examples of such ordinary professional activities would be:
- Occasional lectures, colloquia, seminars, etc., given at colleges and universities and at meetings of professional societies.
- Preparation of monographs, chapters and editorial services for nonprofit educational organizations.
- Service on advisory committees and evaluation panels for government funding agencies, nonprofit foundations and educational organizations.
- Leadership positions in professional societies.
Please note: The annual economic interests reporting requirement administered by the Office of the Board of Regents is separate from and in addition to the outside activities reporting requirement. Pursuant to Wis. Admin. Code § UWS 8.06, the president, vice presidents, chancellors, and all contracting personnel must file a statement of economic interests with the Office of the Board of Regents annually, by April 30.
Activities which are reportable under UWS 8.025 include:
- Professionally related outside activities occurring during the time you are under contract to the university for which you received remuneration, not including ordinary professional activities.
- The names of organizations or businesses for which net remunerative outside activities were performed, the type of activity (consulting, teaching, research, writing, etc.) and the aggregate time spent (days) in that activity. Royalties from writing and patents need be reported only in the year that they first appear.
- You must name the organization or source and indicate the aggregate amount of time in days spent in outside activities with that organization. If you received $5,000.00 or more compensation per year from a single source, you must check the last column of section A. If you believe you should not publicly identify the name of the organization, you must receive approval from your dean to withhold the name (e.g., if revealing the name would be damaging to the organization’s legitimate competitive interests).
- Any remunerative relationships that you had with organizations which sponsor university research, teaching or training in which you are involved. If these relationships exist, you must report the name of the organization.
- Officerships, directorships, trusteeships that you or members of your immediate family hold in businesses or commercial organizations related to your professional field.
- Ownership interests in organizations related to your academic area of specialization, provided that your immediate family collectively owns more than 10% of the equity.
If an apparent conflict of interest is identified, the Institution shall contact their institutional designee for discussion and resolution. If further guidance is needed in developing a conflict management plan, contact the UW System Office of Compliance & Integrity.
Activities which need not be reported include:
- Activities for which remuneration comes from university administered funds (e.g., teaching and innovation awards, etc).
- Remunerative ordinary professional activities (see definitions above).
- Instruction at another nonprofit educational institution or research supported by a government agency if the instruction or research is performed during periods when the staff member is not on the university payroll, or, in the case of part-time appointment, if the work is performed during time not contracted to the university.
Important: while the OAR form gathers information about the prior year, employees are required to report any changes in circumstances as they occur as promptly as possible.
The University Staff Code of Ethics is set forth in section III of Regent Policy Document 20-22: Code of Ethics (RPD 20-22). University Staff are advised to review this policy in its entirety and to abide by the actions identified to avoid possible conflicts between personal interests and public responsibilities as an employee of UW System. When it appears that a material conflict may arise between the personal interests of a University Staff member and his or her public responsibilities, the University Staff member shall notify his or her supervisor or other appropriate administrator by submitting a written statement describing the nature of the possible conflict.
Please note: The annual economic interests reporting requirement administered by the Office of the Board of Regents is separate from and in addition to the outside activities reporting requirement. Pursuant to Wis. Admin. Code § UWS 8.06, the president, vice presidents, chancellors, and all contracting personnel, as defined under UWS 8.02(7), must file a statement of economic interests with the Wisconsin State Ethics Commission by April 30. If you are unsure whether you are defined as a “contracting personnel,” please contact your institution’s Office of Human Resources.
A conflict of interest on the part of the University Staff member exists whenever the University Staff member’s action or failure to act propitiously could reasonably be expected to directly or indirectly produce or assist in producing a private benefit for the University Staff member or the University Staff member’s immediate family or an organization with which the University Staff member is associated. Additional information on code of conduct for University Staff can be found here.
Supervisors and Managers
Any time a supervisor is made aware of a potential conflict of interest, whether through receipt of an Outside Activities Report or through another means, the supervisor should determine whether a potential conflict may exist. This determination should be made within 15 days of when the supervisor is made aware of the potential conflict.
Steps in the Review Process
1. Collect Information:
- Meet with the employee to ask questions related to the potential conflict(s).
- Review conflict of interest guidance available from the Office of Compliance & Integrity:
2. Make one of the following determinations:
- No conflict exists. In this case the employee should be advised that they may continue the outside activity.
- A conflict does exist and cannot be avoided. In this case the employee should be advised to terminate involvement in the activity that causes a conflict.
- A conflict may exist but can be avoided. In this case, the supervisor should work with the employee to create a conflict management plan which outlines how the potential conflict will be avoided. For faculty, academic staff, and limited appointees, these plans should be filed with the Outside Activities Report form.
For guidance on resolving conflicts and creating conflict management plans, please reach out to your institution’s Human Resources Department and/or the UW System Office of Integrity and Compliance.
All UW System Staff
Wis. Admin. Code § UWS 8.035 requires that each institution shall have an institutional ethics committee, “whose function shall be to provide to any member of the unclassified staff consultation and advice on the application” of Chapter UWS 8 Unclassified Staff Code of Ethics. The institutional ethics committee can either be established or designated as part of an existing committee.
Additional resources regarding conflicts of interest are included below.
- Regent Policy Document 13-4: Wisconsin System Policy on Institutional and Employee Relationships with Educational Loan Lenders (RPD 13-4)
- Wis. Admin. Code § UWS 8.025
- Regent Policy Document 20-22: Code of Ethics
- Office of Compliance & Integrity Ethics Information
- UW System Administrative Policy 1290, Code of Ethics
Off-Cycle OAR Reporting
Do you need to report outside activities outside of the annual reporting period in April? Please download the form here and submit it to your supervisor.
Annual Outside Activity Reporting
Due April 30
Employee Instructions: Complete an OAR*
OAR Video: What is this report?
OAR Video: How do I fill out the form?*
OAR Video: What if I have a possible Conflict?
*Note: Select institutions participate in an automated process to complete an Annual Outside Activity Report with UW-Shared Services. These include UW- Eau Claire, UW-Green Bay, UW-La Crosse, UW Oshkosh, UW-Parkside, UW-Platteville, UW-River Falls, UW-Stout, UW-Superior, and UW System Administration. If your institution does not participate in the automated process with UW-Shared Services, please contact your Human Resources department for information on your institutional process.