The following list of activities has been created to provide guidance related to pre-approval and disclosure requirements for different external activities. This table is not exhaustive and meant as guidance. If you are unsure if your external activity requires pre-approval you should err on the side of caution and request pre-approval.
BOT-34 Guidance
Activities that Require Pre-Approval
ACTIVITIES & RELATIONSHIPS (PAID AND UNPAID)
- Consulting, Professional Services, and Other Outside Employment: Any professional activity related to your activities and expertise at IU and involving a contract or legally binding document that is not signed on behalf of IU
- Fiduciary Roles: Board of Directors, Officer, or other fiduciary roles in an external entity related to your university responsibilities, whether compensated or not
- Advisory Role; any advisory role at an entity that is also doing business or contemplating doing business with IU
- Start-ups: Creation of a new company related to your activities and expertise at IU (faculty start-up, non-profit, or consulting company)
- Use of Resources: Any activity involving the use of University resources beyond incidental personal use of IT resources allowed under IT-01
- Gifts, Gratuities, or Benefits: Any item that does not fall under the exemptions listed in the right-side column
ACADEMIC SERVICE (DOMESTIC)
- Activities not listed as exceptions: Any academic service that conflicts with IU commitments or involves a contract between you and another entity
INTERNATIONAL ENGAGEMENTS
(see also Research Security Policy RP-11-012)
- All Appointments: Any appointment, title, or affiliation with a foreign country of concern/entity (paid or unpaid)
- Foreign Talent Programs: Participation in any foreign talent recruitment program (paid or unpaid)
OWNERSHIP & FINANCIAL INTERESTS
- Vendors: Any equity/ownership in a private company that contracts with IU as a supplier
- Overlap:Ownership in a company providing goods/services related to your expertise or scholarship
- Contracting with IU: Plans to sell something or contract with IU as an individual
- Purchasing/Vendor: Any uncompensated role with a company that is currently bidding on a contract with your department
FAMILY INTERESTS (NEPOTISM)
(See also Nepotism and State COI Websites)
- Supervision: Direct or indirect supervision of a family member or romantic partner
- Financial Influence: All situations where any level of control is exerted by an IU employee over IU-related financial activities of a family member or romantic partner. This includes all Principal Investigators and Fiscal Officers with responsibility over accounts from which a family member or romantic partner receives any payment
- Academic Influence: Any situation involving official influence over the academic progress of a family member or romantic partner, including but not limited to teaching classes, participation on academic committees, scholarship award decisions, etc.
- Contracts: Situations where a spouse/dependent has a financial stake in an IU contract or purchase
- State Conflict of Interest: The Indiana Criminal Code requires that new or significant changes in financial interests involving IU be declared for a:
- Spouse
- Child/stepchild/adoptee who is unemancipated and less than 18 years old
- Individual for whom you provide more than ½ support during the year
Activities that Require Annual Disclosure Only
ACTIVITIES & RELATIONSHIPS (PAID AND UNPAID)
- Outside Employment: Paid professional employment or appointments that may not directly overlap with your area of expertise
- IU-Affiliated Entities: Employment or service for:
- IU Foundation
- IU Health
- Eskenazi Health
- VA Hospitals (Roudebush VAMC)
- Affiliated physician practice plans
ACADEMIC SERVICE (DOMESTIC)
- Presentations: Speaking and performances to professional/public audiences (libraries, societies, universities) when compensation is over $5,000 when aggregated together from one entity
INTERNATIONAL ENGAGEMENTS
(see also Research Security Policy RP-11-012)
- Compensated: travel or speaking for non-US entities
PROFESSIONAL SOCIETIES
- Leadership: Any board member, fiscal officer, or director positions
OWNERSHIP & FINANCIAL INTERESTS
- Royalties: Receipt of IP royalties not managed or generated through IU (Commercialization and Innovation Office).
- Publicly Traded Stock: valued over $5,000 or over 5% company related to your University responsibilities
- Non-Publicly Traded Stock or Equity Interest: valued over $5,000 or any equity interest company related to your University responsibilities
Primary And Secondary Responsibilities Or External Activities That Do Not Require Disclosure
ACTIVITIES & RELATIONSHIPS (PAID AND UNPAID)
- Professional Development: Authorized professional development activities
- Uncompensated volunteer activities (e.g., community service, religious organizations, non-profits not related to your research)
- Uncompensated speaking or performance engagements (e.g., at high schools, local libraries, civic groups)
- Helping family members with non-professional tasks or businesses (provided the business is not an IU vendor)
- Gifts, Gratuities, or Benefits:
- Items of de minimus aggregated annual value below $100
- Meals, beverages, or entertainment as part of a business meeting or discussion or in conjunction with attendance at a conference or similar event
- Conference registration waivers from the academic appointee’s or employee’s attendance at the conference or where the academic appointee or employee is a speaker, moderator or other participant
- Payments from U.S. government or not-for-profit entities for:
- Participation in conferences, seminars, lectures or other educational activities
- Participation on boards, advisory committees or review panels
ACADEMIC SERVICE (DOMESTIC)
- US Government Service: Service to US federal agencies (e.g., peer review panels, advisory boards)
- US Academic Institutions:
- Guest lectures or performances at US institutions
- Peer review of colleagues/programs at US institutions
- Advising and mentoring on research activities
- Grant Review: Grant reviewer for US government or US entities
- Book review: Book reviewer for US government or US institution of higher education
- Presentations: Speaking about university work and performances to professional/public audiences (libraries, societies, universities) when compensation is under $5,000
INTERNATIONAL ENGAGEMENTS
(see also Research Security Policy RP-11-012)
- International Conferences: Attending international conferences where you are not receiving an honorarium or personal payment beyond travel reimbursement (unless funded by a foreign government):
- Any international activity that is occurring through IU such as funded research or study abroad
- Uncompensated travel or speaking for non-US entities that are not in countries of concern
PROFESSIONAL SOCIETIES
- Membership & Service: Membership in a US professional society
- Reviewing: Reviewer of book or journal articles
OWNERSHIP & FINANCIAL INTERESTS
- Passive Investments: (e.g., Mutual funds) where you do not control investment decisions
- Supplemental pay from IU: this exception does not include payments pursuant to a contract or purchase
Need help?
If you have any questions about the Kuali COI system or process, please contact the COI Office by phone at 812-856-1706 or email at coi@iu.edu.
