Policy
This policy was a part of the former UPS Policy set that was integrated into the System Administrative Policy set. It applies to all University of Wisconsin institutions except for UW-Madison. For UW-Madison’s policies, please see the Human Resource Design Policies website.
Original Issuance Date: July 1, 2015
Last Revision Date: October 5, 2020
1. Policy Purpose
The purpose of this policy is to provide guidance on the avoidance of activities that cause, or tend to cause, conflicts between employees’ personal interests and their public responsibilities.
2. Responsible Officer
Director of Compliance
3. Scope and Institutional Responsibilities
The policy applies to employees of University of Wisconsin System institutions, excluding UW-Madison.
4. Background
UW System employees are subject to ethics rules covering use of university resources, conflicts of interest, and acceptance of gifts. Pursuant to Wis. Stat. § 19.45(11)(b), the Board of Regents developed Regent Policy Document RPD 20-22, Code of Ethics.
RPD 20-22, Code of Ethics, which was effective July 1, 2015, explains that UW System employees are subject to the following three separate codes:
- Faculty, academic staff, and limited appointees (other than state public officials) remain subject to Wisconsin Administrative Code, Chapter UWS 8.
- State public officials remain subject to subchapter III of Wis. Stats. Chapter 19. Individuals holding the following positions are state public officials: Member – Board of Regents, President, Chancellor, Vice Chancellor, and all Vice President titles.
- Effective July 1, 2015, university staff are subject to a code that is set forth in Section III of RPD 20-22. The University Staff Code of Ethics was closely modeled after Wisconsin Administrative Code, Chapter ER-MRS 24, the Code of Ethics for classified state employees.
5. Definitions
Please see SYS 1225, General Terms and Definitions, for a list of general terms and definitions.
6. Policy Statement
It is the policy of the University of Wisconsin System that chancellors or their designees provide each newly hired employee with the code of ethics to which the employee is subject. Thereafter, chancellors should annually provide all employees with the appropriate code of ethics.
Employees should review, abide by, and ask for clarifications when necessary regarding their respective code of ethics. If an employee is uncertain whether a future action may violate a code of ethics, the employee should consult with the chancellor or the chancellor’s designee.
The employees subject to Wisconsin Administrative Code Chapter UWS 8 must keep track of and report outside activities pursuant to Wis. Admin. Code UWS 8.025. The Board of Regents require all UW System faculty, academic staff, and limited appointees who are subject to UWS 8 with half-time or greater appointments are required to report annually (by April 30 of each year) on outside activities and interests related to their areas of professional responsibility and for which they receive remuneration.
Outside Activities should be reported as specified in SYS 1290.A, Guidelines for Reporting Outside Activities Under UWS 8.025. All reports should be open to public inspection unless confidentiality is allowable by law.
7. Related Documents
Regent Policy Document 13-4, Institutional and Employee Relationships with Educational Loan Lenders
Regent Policy Document 14-8, Consensual Relationships
Regent Policy Document 20-22, Code of Ethics
Compliance & Integrity: Focus Areas – Ethics
Wis. Admin. Code Chapter UWS 8, Unclassified Staff Code of Ethics
Wis. Stat. § 19.45, Standards of Conduct, State Public Officials
Wis. Stat. § 946, Subchapter II, Bribery and Official Misconduct
SYS 1290.A, Guidelines for Reporting Outside Activities Under UWS 8.025
8. Policy History
Wis. Admin. Code Chapter ER-MRS 24, Code of Ethics
Revision 1: October 5, 2020
First Approved: July 1, 2015
9. Scheduled Review
October 2025
Guidance
(Code of Ethics) Guidelines for Reporting Outside Activities Under UWS 8.025
1. Purpose of Guidelines
These guidelines support UW System Administrative Policy 1290, Code of Ethics and describe specific requirements for reporting outside activities.2. Publishing Office(s)
UW System Office of Human Resources3. Affected Stakeholders on Campus
It is the policy of the University of Wisconsin System to require a report from all unclassified staff whose appointments are half-time or more. Chapter UWS 8 of the Wisconsin Administrative Code defines unclassified staff as faculty, academic staff and limited appointees who are not State Public Officials1. If you have a joint appointment, you must file a report for each department/unit.4. Primary Responsibility
You are required to report officerships, directorships, ownership interests, outside professional activities, and remunerative activities that occur at any time during the year, even if you are not under contract to the University for part of that time. If, during the year, changes in your reportable outside activities occur, you should immediately inform, in writing, your dean, director or other appropriate administrator. This information shall be placed on file with your annual statement of outside interests. The due date for the annual report is April 30th each year. Outside professional activities may not create a conflict of commitment with your UW System primary duties. If your aggregate time commitment to one or more outside professional activities will exceed an average of 16 hours per calendar month during hours that you would be normally on duty in your UWS position, you must receive prior written permission from your supervisor.5. Guidelines
A. Reporting Responsibilities
I. Those activities which are reportable under UWS 8.025 include:
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- Remunerative Relationships : Professionally related outside activities occurring at any time during the year, for which you received remuneration, not including ordinary professional activities (see below).
- The names of organizations or businesses for which remunerative outside activities were performed, the type of activity (consulting, teaching, research, writing, etc.), the aggregate time spent in that activity, and whether you received $5,000 or more compensation per year from a single source.
- Royalties from writing and patents need be reported only in the year that they first appear.
- 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).
- If you have received compensation from a nongovernmental sponsor of university research, teaching or training for which you are principal investigator, check the box at the bottom of Section A, Remunerative Relationships and list the name of the sponsor.
- Officerships and Directorships: Officerships, directorships, trusteeships that you or members of your immediate family hold in businesses or commercial organizations related to your professional field.
- Ownership Interests: Ownership interests in organizations related to your academic area of specialization, provided that your immediate family collectively owns more than 10% of the equity.
- Remunerative Relationships : Professionally related outside activities occurring at any time during the year, for which you received remuneration, not including ordinary professional activities (see below).
II. Those activities which need not be reported include:
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- Activities for which remuneration comes from university administered funds (e.g., teaching and innovation awards, etc.).
- Remunerative ordinary professional 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.
- 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.
B. Definitions
A remunerative relationship 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.C. Reviewer Responsibilities
- Managers and Supervisors (or other individual designated by the institution to review outside activity reports) are responsible for reviewing the information provided on outside activity reports submitted by employees and determining whether any reported activities may pose potential conflicts of interest. If the potential for conflict does exist, the manager should meet with the employee to provide guidance on how to avoid conflicts of interest and, if necessary, create a conflict management plan in writing. The reviewer may determine that a conflict does exist and cannot be avoided, in which case the employee should be advised to terminate the activity that causes the conflict.
- Institutions are expected to assess, as part of the review of an outside activity report, how an employee’s time commitment to outside activities may impact their expected contributions to the UW System. The evaluation of a potential conflict of commitment should be a part of the review of an outside activity report. If an employee’s aggregate time commitment to outside activities will exceed an average of 16 hours per calendar month during hours that the employee would normally be on-duty in their UWS position, the employee must receive prior written permission from their supervisor. Individual institutions or departments may impose stricter time limitations, reflecting the local needs and concerns. Supervisors are encouraged to have a written conflict management plan in place in circumstances that may give rise to a conflict of commitment.
- No faculty member or instructional academic staff member shall be absent from their assigned classes, assigned service work or other regular instructional duties for the purpose of engaging in an outside activity, except by the permission of the chancellor or appropriate dean.