BOT-34 Guidance

BOT-34 Guidance

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.

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)

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

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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

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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

FAMILY INTERESTS (NEPOTISM)

(See also Nepotism and State COI Websites)

  • Non-IU Activities: Family activities unrelated to IU business or your supervision

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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.