CONFLICT OF INTEREST PROCEDURES
Senate Procedures 201.1.1
Conflict of Interest: Actual, possible or perceived Conflicts of Interest and/or conflicts of commitment,
including time, as discussed in General Principles 1.1.
Committee: Michigan Tech Conflict of Interest Committee
Coordinator: Michigan Tech Conflict of Interest Coordinator
Member: A member of the Michigan Tech community
Michigan Tech: Michigan Technological University
Michigan Tech Community: All faculty, staff, students, and administrators of Michigan Tech.
Michigan Tech Resources: Includes all facilities such as office space and equipment, as well as
information technology (including web site servers and telecommunications), personnel and stationery.
Policy: The Michigan Tech Conflict of Interest policy for which these procedures were developed
implement (Board of Trustees Policy 3.13).
Procedures: These Conflict of Interest procedures.
Proposal: A proposal for externally funded or sponsored research, education and training activity,
Relative: A member of the Michigan Tech community's spouse, child (by blood, adoption or marriage),
parent, or person with whom the member has a close personal relationship.
Supervisor: Department chair, dean, director; in some cases a researcher, staff, faculty member
administrator other than a chair, dean or director.
Michigan Tech is a complex, dynamic university of which we are proud -- a university
with important goals
and remarkable achievements. For the purpose of these Conflict of Interest procedures, this dynamism has
two consequences. First, though these procedures strive to be comprehensive, these procedures cannot
address every possible situation and do not obviate the need of members to understand and follow other
Michigan Tech policies and procedures. Second, as the market and our collective expertise develop, new
conflict of interest challenges will arise. In applying these procedures, the President and Board of Trustees
relinquish none of their constitutional or statutory authority. Finally, members should be reminded that the
Board of Trustees cannot change or override federal, state or local laws; as such, members must continue
to abide by these laws notwithstanding anything that may appear in these procedures.
1 General Principles
1.1 Conflict of Interest in the university context is a very difficult subject, for it
touches on many different, but
related, topics, including proprietary rights and use of Michigan Tech resources. Conflicts can be divided into
two basic categories. The first covers what many people traditionally associate with the term Conflict of
Interest -- opportunities for inappropriate personal gain during the pursuit of official duties. The gains might
be financial, but may include other forms of benefit such as power or political advantage. The second
category covers conflict of commitment -- the choices individuals make about their professional priorities,
especially the allocation of their time to the different institutions and organizations they serve as
professionals. Members may encounter conflicts of commitment when outside professional activities take
priority over other Michigan Tech-related responsibilities.
1.2 An important function of these procedures is to (i) describe appropriate commercial
normal Michigan Tech business between supervisors, faculty, and other researchers and their staff
subordinates, students and other parties, and (ii) identify when those relationships generate potential or
actual Conflict of Interest and should be disclosed, mitigated (if possible), discouraged, or disallowed.
These procedures identify five categories of activity that may generate Conflicts of Interest: (i) activities
which are usually exempt, (ii) outside professional service activities, (iii) activities or external relationships
with minimal financial interests, including supervision of relatives, and the use of university resources, (iv)
complex external relationships, including business activities and entrepreneurial projects.
1.3 Most situations that pose Conflicts of Interest involve contacts or relationships
members and external entities that compromise, or appear to compromise, the judgment, activities or
perceived loyalty of those individuals. Perception is an especially important but slippery realm, for it is not
guided strictly by "the intentions" and perception can be as damaging to the individual and Michigan Tech as
are clear-cut, open conflicts. Therefore, it is incumbent upon the member to disclose sufficient information
so that any perception of a Conflict of Interest can be addressed and satisfactorily resolved. Michigan Tech
thus will consider how Conflict of Interest appears to an outside third party when applying these procedures.
1.4 These procedures primarily address conflicts emerging from professional activities.
Michigan Tech does
not seek to regulate private decisions that are protected by statute. However, nothing in these procedures
should be construed as allowing any member of the Michigan Tech community to avoid other obligations
under state and federal law. For example, patent and copyright laws must be followed (see Board of
Trustees Policy 18, especially section 1, on Patent and Other Proprietary Rights).
1.4.1 There is a State of Michigan Statute on conflict of interest, MCL 15.301, et seq.
(the "Statute") that
requires that Michigan Tech members disclose any pecuniary interest in a contract with Michigan Tech to the
Board of Trustees, which will make the disclosure a matter of record in its official proceedings. Any member
contemplating a contract with Michigan Tech must disclose this to the Coordinator, who will make a
determination regarding the conflict with respect to the provisions of the Statute, and if required by the
Statute, will report the conflict to the Board of Trustees.
1.5 Michigan Tech's Conflict of Interest policies and procedures rest upon the following:
1.5.1 Upon becoming a member, every individual makes a commitment to Michigan Tech. Those
accept full-time appointments or employment at Michigan Tech must accord Michigan Tech their primary
professional loyalty. These procedures require, therefore, that every member arrange their personal
interests and activities so as not to conflict with their commitment to Michigan Tech. This avoidance of
Conflict of Interest requires that individuals shall not realize improper gain, financial or otherwise, from either
(i) the inappropriate use of Michigan Tech property, funds, equipment, prestige, or other resources; or (ii)
from the exercise of outside professional opportunities that conflict with the conduct of their Michigan Tech
1.5.2 These procedures do not require members to avoid involvement in outside public or
To the contrary, such involvement is often wholly consistent with Michigan Tech's mission to educate its
students and serve the public interest.
1.6 It is vital to the successful performance of Michigan Tech's mission that members
be as free as possible
from Conflicts of Interest. No member may undertake any activity that constitutes an actual or perceived
Conflict of Interest, except as may be expressly approved and/or permitted pursuant to these procedures. It
is each member's responsibility, therefore, to contact the Conflict of Interest Coordinator (Coordinator) if he
or she encounters a Conflict of Interest not contemplated by these procedures or if there is uncertainty
about the existence of a conflict.
1.7 In the event that any member makes any disclosure to any Michigan Tech official pursuant
procedures with respect to an ongoing project or relationship, such member must submit complete and
accurate follow-up disclosure, in the same form as previously submitted, to such Michigan Tech party if
change of circumstances has rendered any previously submitted Disclosure Form materially inaccurate or
1.8 In the event that the Conflict of Interest Coordinator or Committee proposes remedies
for ameliorating, mitigating, or eliminating a member’s Conflict of Interest, these shall be reported to the
1.9 The Michigan Tech Board of Trustees is governed by separate Michigan statutes with
respect to Conflict
of Interest (MCL15.301 and MCL 15.341). As a courtesy, the Board may disclose Conflicts of Interests to
2 Category I: Outside Activities Exempt from Conflict of Interest
Participation in Category I traditional professional activities do not typically create
Conflicts of Interest or
commitment (but see section 6.2), and as such do not normally have to be fully disclosed to the Coordinator.
Category I activities include, but are not limited to:
- attending professional meetings;
- writing books, articles, and research reports; creating works of art, performances and exhibitions;
- giving lectures, symposia, speeches, colloquia at other universities;
- conducting site visits and program evaluations at other universities; and
- refereeing manuscripts for journals and publishers.
If a member has reason to believe that an ordinarily benign Category I activity may
create a Conflict of
Interest, they must fully disclose this potential Conflict of Interest to the Coordinator prior to participation in
the proposed activity. The Coordinator will promptly determine whether the proposed activity would
constitute a Conflict of Interest, and in consultation with the member, settle upon an appropriate course of
3 Category II: Outside Professional Service Activities Which Create Conflicts of Interest
3.1.1 Activities that may generate Category II Conflicts of Interest include:
- providing brief consulting services related to a member's area of professional expertise,
involving one-time engagements with businesses, nonprofit entities, educational institutions, or
government agencies; and
- providing brief outside professional service with or without compensation for any
entity or organization, whether or not the work is performed on campus. Work that constitutes outside
professional service requires distinctive training, expertise and/or certification sufficient to qualify the
member for paid employment at Michigan Tech, or where such activity in itself is a basis for paid work
in the marketplace. Such outside professional service includes, without limitation, editorships,
secretariats, and other administrative functions in national or regional organizations and academic
societies. Work during the 9-month academic year supported by a grant or contract awarded to
Michigan Tech and duly authorized under Michigan Tech policies does not constitute outside
3.1.2 Activities that do not generate Category II Conflicts of Interest include:
- providing outside community service. For some members, however, the distinction between
community service and professional service will be difficult to determine. Thus:
- in cases where the community service relates to the member's distinctive training
or expertise, if a
member has reason to believe that their provision of outside community service may constitute
providing outside professional services, then the proposed activity will be deemed to be outside
professional services and, as such, subject to these procedures as a Category II activity.
3.2 Category II Guidelines
3.2.1 Members should not allow their outside service activities to interfere with their
to Michigan Tech.
3.2.2 The time and attention devoted to rendering an outside professional service must
not have priority
over routine Michigan Tech obligations, unless the member has been appropriately released from those
3.2.3 By way of guidance, members may not engage in Category II activities in excess of
an average of one
day per week, up to a maximum of 38 days during the regular academic year. Faculty and professional staff
may, upon approval of their supervisors, be extended the limited privilege of flexible scheduling of some
working hours so that some Category II activities in excess of this level are performed during normal
working hours during the period required to accomplish the service or activity.
3.3 Disclosure and Review
3.3.1 Each Member must promptly and fully disclose in writing to their immediate supervisor
member engages in any Category II activities, whether or not it will result in a conflict of interest.
3.3.2 If an immediate supervisor determines that a Category II activity creates a Conflict
of Interest or is
otherwise detrimental to the college's, school's, department's, or individual's primary duties, he or she may
require that the member submit to special oversight or management procedures or to cease such activity.
Members may appeal their supervisor's decision to Michigan Tech's Conflict of Interest Coordinator.
4 Category III: External Relationships and Activities With Minimal Financial Interests
Certain aspects of the efforts of members to serve their professions or the wider
community may create
opportunities for members to benefit monetarily from those efforts, over and above their regular salary or
compensation. These opportunities include professional consulting; adoption of self-authored textbooks or
other course materials; royalties from patents; sponsored research, education and training proposals;
routine testing; and the ownership and operation of small businesses not directly related to the member’s
Michigan Tech responsibilities. Michigan Tech encourages these activities in the belief that such contacts
and the activities benefit Michigan Tech, its faculty members and students, and the wider community. But
Conflicts of Interest and particularly conflicts of commitment are inherent in these activities. When
compensation is small, the primary conflict is likely to be a conflict of commitment, as a member diverts his
or her time from regular responsibilities from Michigan Tech to an outside professional activity. The first step
in mitigating such a conflict is prior disclosure of the activity to the member's immediate supervisor. In some
cases, additional required actions are described in the guidelines below.
In addition, two activities that are deemed Category III activities are use of university
supervision of relatives.
Category III activities include providing consulting services by a member on more
than a one-time basis
where such services are related to the member's area of professional expertise. Professional activities or
outside employment of any type undertaken by faculty on nine-month appointments during the summer
term, however, are not considered Category III activities.
4.1.1 Category III Consulting Guidelines
22.214.171.124 Faculty members on nine-month appointments may provide consulting services during
that ninemonth period only when the individual's primary duties in the classroom,
research, and other academic
areas continue to be performed at a high standard. (Also see section 4.1.3).
126.96.36.199 Faculty members, research staff or administrators on twelve-month appointments may
consulting on a limited basis only, because of the demands placed on their time by Michigan Tech. (Also see
188.8.131.52 Any Category III consulting that overlaps with or takes place in the context of Proposals
4.4) will be reviewed by the Coordinator to determine if the activity should be considered Category IV and
follow the procedures thereto (see section 5).
184.108.40.206 A full-time member may not engage in Category III activities in excess of the equivalent
of one day
per week during the regular academic year, up to a maximum of 38 days. Should the member be required to
be absent from work or to miss meeting regularly scheduled classes in order to engage in the Category III
activity, the member’s supervisor must approve the absence in advance.
220.127.116.11 Members may not divert work from Michigan Tech that would normally be funded through
research or other proposals into their own Category III consulting activity for the purpose of avoiding
payment of Michigan Tech overhead or to reduce third party costs.
18.104.22.168 Members may not compete with professional or instructional services offered by Michigan Tech.
22.214.171.124 Members may not accept consulting contracts that could be perceived as conveying
advantage to third parties due to the member's employment at Michigan Tech.
126.96.36.199 Members must not accept consulting contracts that expose the individual or Michigan
Tech to actual
or apparent conflicts arising from multiple concurrent financial, advisory, or occupational programs.
188.8.131.52 Faculty and staff members with financial relationships outside of Michigan Tech who
can apply for
sponsored funding should not allow such pursuits to interfere with their pursuit of sponsored funding for
Michigan Tech. In situations where Michigan Tech and the outside entity can apply for the same funding,
Michigan Tech has first priority in making application and the member may not cause the outside entity to
compete with Michigan Tech funding applications. Members must first discuss such ideas or proposals with
their supervisors in such situations. The investigator must recognize that he or she owes appropriate time
and effort to Michigan Tech's search for sponsored projects.
4.1.2 Disclosure and Review
184.108.40.206 Before engaging in Category III consulting activities, members must fully disclose
in writing to their immediate supervisors. Supervisors may require that the member submit to special
oversight or management procedures or to cease such activities, if they determine that such activities
constitute a Conflict of Interest or are otherwise detrimental to the college's school's, department's, or
individual's primary duties, especially if consulting places excessive or disproportionate demands (e.g., see
section 220.127.116.11) on the time, energy, or intellectual effort of the individual involved. Members may appeal
their supervisor's decision to the Coordinator.
18.104.22.168 Supervisors may permit faculty members or researchers to adopt a limited flexible
work schedule so
that some consulting services may be performed during what would otherwise be normal working hours
during the period required to accomplish the service or activity.
4.2 Adoption of Self-authored Textbooks and Other Course Materials
22.214.171.124 "Textbooks" are books sold to students that are (i) published by commercial or university
(ii) assembled and/or published within Michigan Tech or through local duplication services.
126.96.36.199 "Course Materials" are non-book instructional materials sold to students that are
(i) published by
commercial or university presses; or (ii) material assembled and/or published within Michigan Tech or
through local duplication services.
188.8.131.52 Faculty may not sell instructional materials directly to students.
184.108.40.206 All textbooks and course materials adopted for a class must represent, in the instructor's
professional opinion, the most appropriate choice for that class and the students within it.
220.127.116.11 Members must select books and course materials according to the merit and appropriateness
these items, not for personal financial gain.
4.2.3 Disclosure and Review
18.104.22.168 Faculty who receive royalties from the sale of textbooks or course materials must
disclose the use of
such works to their chair or dean for approval.
22.214.171.124 If the chair's or dean's review determines that a member's use of member-authored
course materials constitutes a Conflict of Interest or is otherwise detrimental to the college, school,
department, or Michigan Tech, the chairperson may require the member to submit to special oversight or
management procedures or to cease the use of such textbooks or course materials. Members may appeal
the chairperson's decision to the Coordinator.
4.3 Royalties from Patents
126.96.36.199 Members may work on or assign students, postdoctoral fellows, or other trainees to
projects in which that member or a relative is entitled to receive royalties or licensing fees from patents or
patent applications, but has no other financial interests in that project, provided that the roles are made clear
in writing to their immediate supervisor and the Coordinator.
188.8.131.52 Per the terms of each employee’s and graduate student's Patent, Research and Other
Rights Agreement, and Michigan Tech’s Board of Trustees Policy (Chapter 18), developments made while
individuals are employed by Michigan Tech must be assigned to Michigan Tech. Use of technologies that
are covered under this agreement and related policies can only be conducted under appropriate license or
other agreements. Individuals interested in beginning entrepreneurial activities based on developments that
have occurred during their course of employment should consult the Office of Intellectual Property and
Technology Commercialization to determine if a license is necessary and to begin discussing licensing
4.3.2 Disclosure and Review
Members who are entitled to receive royalties (or licensing fees) in connection with
projects and continue to
conduct research related to the subject for which they are receiving royalties must fully disclose in writing
the existence of these royalty payments to their immediate supervisor and the Coordinator before continuing
their research or assigning others to the project. To avoid doubt, this disclosure must include the nature and
circumstances of the assistance provided by and compensation provided to students, postdoctoral fellows,
or other trainees to such projects. The Coordinator may require the member to submit to special oversight or
management procedures or to cease such activities altogether, and will inform the member’s supervisor of
such procedures. Members may appeal the imposition of any such remedy or mechanisms to the
4.4. Proposals (Sponsored Research, Education/Training, and other Proposals)
4.4.1 Category III Proposal Guidelines
184.108.40.206 Members that submit proposals and who conduct ongoing research and collaborations
Tech funded by outside third parties must avoid if possible, and disclose if unavoidable, all Conflicts of
Interest including, without limitation: (1) the existence of financial connections between the project staff,
including the investigators, and research sponsor or client; and (2) financial involvement by investigators
and/or other members of the research team with an outside business enterprise in the same or a related
research area through consulting or other business activities.
4.4.2 Disclosure and Review
220.127.116.11 If no Category III (or IV or V) Conflict of Interest exists for a given proposal,
the principal or
cooperating investigator indicates on the Michigan Tech transmittal form that the proposal does not present
a conflict of interest, and by signing the transmittal form, certifies that the investigator(s) have read these
procedures and are in compliance with them.
18.104.22.168 If a Category III (or IV or V) Conflict of Interest exists for a proposal, each investigator
must submit to
the Coordinator a completed Conflict of Interest Cover Sheet and Disclosure Form ("Disclosure Forms") at
the time of submission of each such proposal. If there are multiple investigators, Disclosure Forms must be
submitted by each investigator.
22.214.171.124 Distinct Disclosure Forms must be submitted to the Coordinator for each separate
including proposals to continue ongoing currently sponsored research. The Coordinator will keep this
information as confidential as possible.
126.96.36.199 The Coordinator will review the submitted Disclosure Forms for Conflict of Interest.
If the Coordinator
identifies a real, potential, or perceived Conflict of Interest, the Coordinator will work with the investigator(s)
to propose remedies or mechanisms for ameliorating, mitigating, or eliminating the Conflict of Interest, or will
disapprove the proposed activity. These remedies or mechanisms need not be finalized before submission
of the proposal, but must be finalized to the satisfaction of the Coordinator before funds may be expended
by any investigator. Members may appeal the imposition of any such remedy or mechanisms to the
188.8.131.52 After the review the Coordinator will attach a signed internal review form to each
contract or grant
proposal, indicating the satisfactory resolution of any Conflicts of Interest. The satisfactory signed internal
review form must be in the proposal file in order for Michigan Tech to release funds to the principal
investigator. Normally this review, including these forms, is not transmitted to funding agencies. If funding
agencies request copies of these forms, the Coordinator will confer with Research and Sponsored Programs
and the PI before releasing any information.
184.108.40.206 In the event that the Coordinator is off campus and unable to review external research
proposals for potential Conflicts of Interest, other designated MTU representatives will be authorized to
conduct the Conflict of Interest review and to sign the internal review form. Cover Sheets and Disclosure
Forms so reviewed by designated Michigan Tech representatives, and the internal review form, must then
be transmitted to the Coordinator for subsequent verification.
220.127.116.11 If a new Conflict of Interest arises after receipt of a research award, or if the
Conflict of Interest
situation changes after receipt of a research award, the investigator(s) must submit to the Coordinator
updated Disclosure Forms. The Coordinator will review the submitted Disclosure Forms for Conflict of
Interest. If the Coordinator identifies a real, potential, or perceived Conflict of Interest, the Coordinator will
work with the investigator(s) to propose remedies or mechanisms for ameliorating, mitigating, or eliminating
the Conflict of Interest, or will disapprove the proposed activity. These remedies or mechanisms must be
finalized to the satisfaction of the Coordinator before additional funds may be expended by any investigator.
Members may appeal the imposition of any such remedy or mechanisms to the Committee.
18.104.22.168 Testing is defined as the performance of a standard test that provides the sponsor
with results and
does not involve an analysis of those results.
4.5.2 Disclosure and Review
22.214.171.124 Members engaged in testing must submit Disclosure Forms to the Coordinator on an annual
with respect to such testing if a Conflict of Interest exists.
126.96.36.199 After reviewing the Disclosure Forms, the Coordinator may require the member to submit
oversight or management procedures or to cease such testing altogether. Members may appeal the
decision of the Coordinator to the Committee.
4.6 Small Businesses Not Directly Related to the Member’s Michigan Tech Responsibilities
188.8.131.52 Category III activities include owning and operating a small business outside of Michigan
Tech in an
area not directly related to the member’s Michigan Tech responsibilities or areas of expertise. The
ownership or operation of a small business during the summer term by faculty, staff or administrators on
nine-month appointments, however, is not considered a Category III activity.
184.108.40.206 Faculty members, staff or administrators on nine-month appointments may own or operate
businesses during that nine-month period. Nonetheless, this business should not interfere with the
individual's primary Michigan Tech duties. (Also see section 4.6.3).
220.127.116.11 Faculty members, staff or administrators on twelve-month appointments may own or
operate a small
business on a limited basis only, because of the demands placed on their time by Michigan Tech. (Also see
18.104.22.168 Should the member be required to be absent from work or to miss meeting regularly
classes in order to engage in the Category III activity, the member’s supervisor must approve the absence in
22.214.171.124 Members may not divert work from Michigan Tech that would normally be funded through
research into their own Category III small business for the purpose of avoiding payment of Michigan Tech
overhead or to reduce third party costs.
126.96.36.199 Members may not compete with professional or instructional services offered by Michigan Tech.
188.8.131.52 Members may not accept business contracts that could be perceived as conveying competitive
advantage to third parties due to the member's employment at Michigan Tech.
184.108.40.206 Members must not accept business contracts that expose the individual or Michigan
Tech to actual
or apparent conflicts arising from multiple concurrent financial, advisory, or occupational programs.
220.127.116.11 Faculty and staff members with financial relationships outside of Michigan Tech who
can apply for
sponsored funding should not allow their small business to interfere with their pursuit of sponsored funding
for Michigan Tech. In situations where Michigan Tech and the outside entity can apply for the same funding,
Michigan Tech has first priority in making application and the member may not cause the outside entity to
compete with Michigan Tech funding applications. Members must first discuss such ideas or proposals with
their supervisors in such situations. The investigator must recognize that he or she owes appropriate time
and effort to Michigan Tech's search for sponsored projects.
4.6.3 Disclosure and Review
18.104.22.168 It is in the best interest of members to disclose the proposed activity in writing
to their immediate
supervisors or to the Coordinator before engaging in Category III business ownership or operation.
Supervisors or the Coordinator may require that the member submit to special oversight or management
procedures or to cease such activities, if they determine that such activities constitute a Conflict of Interest
or are otherwise detrimental to the college's school's, department's, or individual's primary duties, especially
if the business places excessive or disproportionate demands (e.g., see section 22.214.171.124) on the time, energy,
or intellectual effort of the individual involved. Members may appeal their supervisor's decision to the
Coordinator, or the Coordinator’s decision to the Committee.
4.7 Use of University Resources
126.96.36.199 Category III activities include the use of Michigan Tech resources in connection
with any work
undertaken by members for outside activities.
4.7.2 Category III Use Guidelines
188.8.131.52 Correspondence and reports related to outside activities must not be written on Michigan
stationery, nor shall such correspondence or reports identify the member as representing Michigan Tech.
184.108.40.206 Members should abide by Michigan Tech policies, such as the Michigan Tech Computer
and University Web Policy, that govern use of Michigan Tech resources.
220.127.116.11 Members engaged in outside activities involving more than minimal use of Michigan
or resources as determined by the supervisor, department chair or dean, must make special arrangements
to schedule the use of those resources. Members must reimburse Michigan Tech for any Michigan Tech
resources, including small-scale office or laboratory equipment, used during the provision of work for outside
entities for which they receive direct compensation. If actual costs cannot be determined or a use fee
negotiated, the cost of using Michigan Tech facilities will be deemed to be fifteen percent (15%) of any gross
revenues (such as a consulting fee) received by the member in connection with the provision of services
during which the member used Michigan Tech facilities.
4.7.3 Disclosure and Review
18.104.22.168 Before engaging in the use of Michigan Tech resources in connection with any work
outside sponsors, members must fully disclose in writing to their immediate supervisors the extent to which
the proposed activity will utilize Michigan Tech resources. Supervisors may require that the member submit
to special oversight or management procedures or cease such activities, if they determine that such
activities constitute a Conflict of Interest or are otherwise detrimental to the college's, school's, department's,
or individual's primary duties. Members may appeal their supervisor's decision to the Coordinator.
4.8 Supervision of Relatives
22.214.171.124 This procedure is intended to prevent members from being accused of unfairly or inappropriately
advancing the interests of a family member or relative. This policy also applies to principal and cooperating
investigators conducting sponsored research or other programs. Primary responsibility for avoiding
situations that create the appearance of conflict of interest falls on the member or investigator.
126.96.36.199 Under no circumstances may members initiate or participate in Michigan Tech decisions
direct monetary or non-monetary benefit to a relative as defined in Board of Trustees Policy 3.8 (spouses,
brothers, sisters, sons, daughters, and parents) or person with whom member has close personal
relationship including, without limitation, decisions related to initial appointment, retention, promotion, salary
determination, travel, leave of absence, stock shares or profits, stock options, and initial public offerings.
188.8.131.52 Members should exercise caution in their involvement with Michigan Tech decisions
relatives or a person with whom the member has a close personal relationship.
184.108.40.206 Members who serve as principal and cooperating investigators of proposals or participate
programs funded by outside agencies and conducted through Michigan Tech must at all times abide by
Michigan Tech policies and procedures regarding hiring and supervision of relatives and related rules
regarding procurement during the life of the grant or contract.
4.8.2 Disclosure and Review
220.127.116.11 If any member serves in a supervisory role to a relative, then such member must fully
relationship to his or her immediate supervisor. Supervisors may require the member to submit to special
oversight or management procedures or require alternative supervisory responsibility for the relative.
Members may appeal the supervisor's decision to the Coordinator. Members have the primary responsibility
for avoiding this type of conflict of interest, and should excuse themselves from any situation that might
create even the appearance of nepotism. When in doubt, members should step aside from potential
conflicts of interest and seek advice from higher administrators, who may appoint alternate supervisors for
18.104.22.168 Principal investigators and cooperating investigators of proposals must fully disclose
in writing to
their immediate supervisor and to the Coordinator their intent to hire relatives or include relatives as
investigators on the proposal at the time they submit grant and contract proposals to Michigan Tech for
approval and justify such a decision. The Coordinator will work with the investigator(s) to propose remedies
or mechanisms for ameliorating, mitigating, or eliminating the Conflict of Interest, including requiring the
member to submit to special oversight or management procedures or requiring alternative supervisory
responsibility for the relative, or the Coordinator will disapprove the proposed activity. These remedies or
mechanisms need not be finalized before submission of the proposal, but must be finalized to the
satisfaction of the Coordinator before funds may be expended by any investigator to hire the relative.
Members may appeal the Coordinator’s decision to the Committee.
5 Category IV: Complex External Relationships, Including Outside Business Activities
Certain external relationships entered into by members, by their very nature, pose
complicated Conflict of
Interest problems. For example, Michigan Tech, like most state universities, is expected to contribute to the
state's economic development by encouraging the movement of new ideas, processes, and technologies
developed by members into the marketplace. On occasion, members have sought to turn ideas into
marketable products, jobs, and profits. Adherence to the disclosure and review provisions of this policy will
help avoid improper preferential treatment to individual business enterprises that involve members. It will
also help to delineate more clearly where activities that are part of a member’s Michigan Tech
responsibilities end, and where outside activities begin, when Michigan Tech employees have private
business interests related to their professional university responsibilities. The possibility of financially
benefiting outside entities, as well as one's self, further clouds the issue. Finally, it is also possible for
research efforts by members who are connected to outside business interests to take unfair advantage of
the university's resources, since these resources are not available to potential competitors.
5.1.1 A member is normally deemed to be engaging in Category IV activities when that member
significant financial interest of $10,000 or more per year in any outside activity related to their Michigan Tech
responsibilities, i.e., (i) a significant financial interest that would reasonably appear to be affected by the
research, educational and/or professional activities of the member, in particular sponsored research
activities, or (ii) a significant financial interest in entities whose financial interests would reasonably appear
to be affected by such activities. The term “significant financial interest” means anything of monetary value,
including but not limited to, salary or other payments for services (e.g. consulting fees or honoraria); equity
interest (e.g. stocks, stock options or other ownership interests); and intellectual property rights (e.g.
patents, copyrights and royalties from such rights). The term does not include salary, royalties or
reimbursements from MTU; income from seminars, lectures or teaching engagements sponsored by public
or non-profit entities; income from service on advisory committees or review panels for public or nonprofit
entities; equity interests, when aggregated for spouse and dependent children, which do not exceed
$10,000 in value and do not represent more than a 5% ownership interest in a single entity; salary, royalty or
other payments, when aggregated for spouse and dependent children, which do not exceed $10,000 in a
However, Category IV activities defined below in 22.214.171.124-126.96.36.199 require disclosure
even if the financial
interest has not yet reached the $10,000 threshold. Category IV activities include, but are not limited to:
188.8.131.52 participation in testing, trials, research, evaluation, or development of a technology,
process, product, hardware or software owned or controlled by a business in which the member, a relative,
or an associated entity (trust or any other enterprise over which the individual exercises a controlling
interest) has a consulting relationship, sits on a board of directors, holds stock or stock options or similar
ownership interest, or has any other financial interest;
184.108.40.206 assignment of students, postdoctoral fellows, or other trainees to projects supported
by a business
(either as sponsored research or as a gift) in which the member, a relative, or an associated entity (trust or
any other enterprise over which the individual exercises a controlling interest) has a financial interest other
than royalties under Michigan Tech policies;
220.127.116.11 participation in, or taking administrative action on, Michigan Tech-supervised activities
via grants and
contracts, purchase orders, lease arrangement, rentals, and/or donations from a business in which the
member, a relative, or an associated entity (trust or any other enterprise over which the individual exercises
a controlling interest) has a consulting relationship, holds stock or similar ownership interest, has any other
financial interest (other than royalties under Michigan Tech policies), or serves on the board of directors or
18.104.22.168 assumption of an executive position in a business engaged in commercial or research
related to his/her Michigan Tech responsibilities;
22.214.171.124 holding of a financial interest in a business related to the member's Michigan Tech
that competes or has the potential to compete with services, products, or bids for sponsored research by
126.96.36.199 taking any action on behalf of Michigan Tech that is beneficial to a business in
which the member, a
relative, or an associated entity has a financial interest.
5.2 Category IV Guidelines
5.2.1 Early efforts to establish a business to commercialize the results of an individual's
research may require some latitude in these areas. Members interested in beginning entrepreneurial
activities based on developments that have occurred during their employment at Michigan Tech should
consult the Office of Intellectual Property and Technology Commercialization to determine if a license is
necessary (see 188.8.131.52) Once an enterprise has been established by a member or involving a member, he
or she must clarify the relationship between Michigan Tech and the business with which he or she has
financial interests. In particular, the member’s role in the business and the relationship between the
member’s Michigan Tech and business activities must be disclosed to the Coordinator. In addition, if
students are involved in this activity, members must fully disclose to the students the relationship between
Michigan Tech and the business.
5.2.2 Members engaging in Category IV activities must abide by the Category III guidelines
for use of
university resources (see 4.7 above) and supervision of relatives (see 4.8 above).
5.3 Category IV Disclosure and Review
5.3.1 Members who engage in any Category IV activity including research and consulting,
timely, complete and accurate Disclosure Forms to their immediate supervisor and the Coordinator in
advance of pursuing that activity. Filing these forms with the Coordinator will begin the process of seeking
permission to engage in Category IV activities. All new Category IV activities must be reviewed and
approved by the Committee. The supervisor, Coordinator and the Committee will keep this information as
confidential as possible.
5.3.2 After reviewing the Disclosure Forms the Coordinator may require the member to submit
oversight or management procedures or to cease such Category IV activity altogether. Members may
appeal the Coordinator's decision to the Committee.
5.3.3 All members with a Category IV Conflict of Interest must submit an annual report
to the Coordinator
with an update of all his or her Category IV activities over the previous 12 months. This report will normally
be submitted in April, and the Coordinator will review this report within two weeks.
6 Category V: Other Activities and Conflicts
Purchasing is an area where concerns about Conflict of Interest traditionally have
focused, given the
opportunities that exist for an employee to benefit inappropriately from official activities. Michigan Tech's
purchasing procedures are designed to protect Michigan Tech employees from the appearance of taking
unfair advantages or making inappropriate gains through their control of University purchases. The
procedures also protect Michigan Tech and insure that individuals responsible for purchases are not in a
Conflict of Interest and abusing their position.
184.108.40.206 MTU's purchasing policy seeks to use disclosure mechanisms to insure that the marketplace,
personal financial gain, guides purchasing decisions.
220.127.116.11 All members authorized to and engaged in purchasing on behalf of Michigan Tech in
18.104.22.168.A Give first consideration to the objectives, policies and procedures of Michigan Tech.
22.214.171.124.B Strive to obtain the maximum ultimate value of each dollar of expenditure.
126.96.36.199.C Cooperate with trade and industrial associations in the promotion and development
188.8.131.52.D Demand honesty in sales representation whether offered through the medium of an oral
statement, an advertisement, or a sample of a product.
184.108.40.206.E Decline personal gifts, gratuities, goods, services, and trips, which might in any
way influence the
purchase of materials.
220.127.116.11.F Grant all competitive bidders equal consideration, to regard each transaction on
its own merits, to
foster and promote fair ethical and legal trade practices.
18.104.22.168.G Accord a prompt and courteous reception insofar as conditions permit to all who call
22.214.171.124.H Counsel and cooperate with National Association of Educational Buyers members and
a spirit of unity among them.
126.96.36.199 Purchases may be made from firms in which a member or a relative has a financial
upon prior, written disclosure to the Coordinator and written approval by the member's immediate
6.1.2 Disclosure and Review
188.8.131.52 Members authorized to and responsible for purchasing equipment or services for Michigan
must fully disclose in writing any financial relationships with potential vendors to the Coordinator upon each
purchase requisition. A member must disclose any level of ownership in, or control of, a company with which
such member intends to do business using Michigan Tech funds, equipment, expertise, or influence, for any
level of financial relationship.
184.108.40.206 Members authorized to and responsible for purchasing supplies or services under research
sponsored projects also must comply with the guidelines and standards specified in the individual contracts,
as well as with all Michigan Tech policies and procedures. If there is a conflict between the different
applicable policies and procedures, the member must resolve the conflict with the advice of the Coordinator.
220.127.116.11 Members who exercise a significant measure of control over purchases because of their
(buyers, department chairs, Michigan Tech officers) or because they must approve certain purchases
(deans, upper-level administrators, Board of Trustees members, etc.) must file financial disclosure forms
with the Coordinator if there is a Conflict of Interest.
18.104.22.168 After reviewing submitted Disclosure Forms, the Coordinator may require the member
to submit to
special oversight or management procedures or to reverse the purchasing decision altogether. Members
may appeal the Coordinator's decision to the Committee.
6.2 Business Referrals (see end note 1)
22.214.171.124 Except within the context of consulting activities that conform to Michigan Tech's
consulting (see sections 3.1.1 and 4.1 and 4.2), a member, while acting in the context of his or her Michigan
Tech duties, may not make professional referrals to a business or outside entity in which he/she, a relative,
or an associated entity has a financial interest.
126.96.36.199 To obtain advice untainted by potential or perceived Conflicts of Interest, Michigan
must apply the principle of separation of functions when retaining consultants or purchasing products. In this
context, the term "function" pertains to advising versus performance of tasks.
188.8.131.52 Michigan Tech must normally disqualify a consultant who serves as an uncompensated
Michigan Tech from receiving compensation for providing services to Michigan Tech. Michigan Tech
normally must not accept advice from a consultant that refers Michigan Tech to an enterprise in which the
consultant has a financial interest.
6.2.2 Disclosure and Review
184.108.40.206 A member may make exceptions to these procedures in cases where Michigan Tech clearly
from not separating advice and service into separate functions. Any exception to these section 6.2
guidelines must be approved in advance by the Coordinator and the member's immediate supervisor.
6.3 Business Relationships with Subordinates
When a supervisor enters into a business relationship with a subordinate not involving
a conflict could arise concerning potential or perceived coercion. Most business or consulting relationships
are routine, acceptable and should be encouraged. Some types of contractual, business relationships are
more serious and need more detailed disclosure, and may be prohibited. An example of a relationship that
may be prohibited, and that must be disclosed and reviewed by the Coordinator, is a partnership that makes
the student (or subordinate) a co-owner or officer of a business, where the differential in power puts the
student (or subordinate) in an unfair bargaining position and compromises the advisor's (or supervisor's)
primary responsibility to Michigan Tech. Such a business relationship is especially problematic if it involves
220.127.116.11 Members may occasionally hire students or subordinates to do work for them unrelated
member's Michigan Tech responsibilities (e.g., yard work) or in a business setting (e.g., the hiring of
students to do survey work or testing as part of a consulting project). These activities are reasonable as long
as there is no coercion involved and fair and reasonable compensation is provided.
18.104.22.168 In rare cases, members may enter into contractual or business relationships involving
actual or potential financial interests with students that they supervise provided that members sever their
Michigan Tech supervisory relationship with the student prior to negotiating the contract or business
relationship. This supervisory relationship may be maintained, however, at the request of the member and
the student, and with the prior approval of the member's chair, dean, or director and the Coordinator.
6.3.2 Disclosure and Review
22.214.171.124 Under cases described in section 126.96.36.199, members must notify their immediate supervisor
hiring subordinates or students whom they advise or from their courses. The immediate supervisor may
require the member to submit to special oversight or management procedures or to reverse the
contemplated hiring altogether. Members may appeal the supervisor's decision to the Coordinator.
188.8.131.52 Under cases described in section 184.108.40.206, members must notify their immediate supervisor
Coordinator. The immediate supervisor and/or Coordinator may require the member to submit to special
oversight or management procedures or to eliminate the contemplated relationship altogether. Members
may appeal the supervisor's and/or Coordinator's decision to the Committee. To avoid doubt, in such
circumstances the immediate supervisor and/or Coordinator will normally require that a faculty member be
replaced as the student's advisor. The involved student has a right to discuss issues related to activities
described in this section with the faculty member's immediate supervisor and/or the Coordinator prior to the
imposition of any conditions upon the faculty member.
7 Review and Enforcement
7.1.1 Supervisors have substantial responsibility to work with faculty and staff in their
resolve Conflicts of Interest. They should seek the advice of the Coordinator as necessary.
7.1.2 Supervisors must submit to the Coordinator an annual report of conflicts of interest
that they have
resolved in their department. This will assist the Coordinator in preparing the Coordinator’s annual report to
the Provost and Board of Trustees.
7.2 MTU Conflict of Interest Coordinator
The Provost and Senior Vice President for Academic and Student Affairs must designate
a Coordinator with
an academic background and a familiarity with the academic and research process. The Coordinator's
primary responsibility will be to review submitted Disclosure Forms and in cases of Category III, IV or V
activities to determine appropriate mitigation procedures whenever possible. The Coordinator will have the
authority to certify that Michigan Tech is in compliance with the Conflict of Interest guidelines or regulations
of external funding agencies as well as those of Michigan Tech and the State of Michigan. The Coordinator
will work with members to identify means of minimizing or eliminating potential Conflicts of Interest. The
Coordinator also will have the authority to contact funding agencies in the event that Conflicts of Interest
cannot be resolved under these procedures. The Coordinator will confer with Research and Sponsored
Programs before releasing any confidential information.
The Coordinator will develop procedures to hear appeals of decisions made by supervisors
and will retain
records connected to Coordinator-level Conflict of Interest reviews for three years after each project is
completed. The Coordinator will request and must receive from supervisors an annual report that
summarizes Conflicts of Interest disclosed to supervisors, and must prepare annual reports for the Provost
and Board of Trustees that includes a summary of Conflict of Interest activities during the previous year.
The Coordinator will serve as a resource for members seeking to gain more information
about Conflicts of
Interest, how to avoid them, and how to mitigate and resolve conflicts that occur. The Coordinator will assist
in the completion of Disclosure Forms by members in a fashion analogous to Michigan Tech research staff
who help prepare budgets and financial statements for sponsored research proposals to outside agencies.
The Coordinator will play the role of facilitator and educator on the subject of Conflict of Interest at Michigan
Tech and will work with members in seeking resolutions to Conflicts of Interest. Finally, members who have
concerns about Conflicts of Interest involving other members may contact the Coordinator about their
All communications with the Coordinator will normally be kept confidential. Members
will have an
opportunity to work with the Coordinator to identify and eliminate their conflicts of interest. The Coordinator
must contact immediate supervisors about any unremedied Conflicts of Interest so that they may be
examined pursuant to these procedures.
7.3 MTU Conflict of Interest Committee
7.3.1 The Committee will review all activities that fall under Category IV, as well as
seeking external funding that contain Conflicts of Interest that cannot be resolved by the Coordinator, in a
timely manner. The Committee is a permanent committee elected by the Michigan Tech Senate, consisting
of three members from the Senate constituency (faculty and staff), with staggered terms, in addition to the
Coordinator as an ex officio member. It is anticipated that relatively few cases will require such a review. But
for these reviews, the Committee may add, on a case-by-case basis, additional members as necessary.
These additional members will be appointed by the President of the Michigan Tech Senate and the Michigan
Tech administration based on their knowledge of the applicable field of expertise as well as knowledge of
Conflict of Interest and intellectual property issues.
7.3.2 The charge to this Committee includes the following, without limitation:
- serve as an advisory Committee for the Provost and Senior Vice President for Academic
Affairs and to assess the current situation in Michigan Tech with respect to applying the Conflict of
Interest policy and procedures;
- inform the University Senate on the Michigan Tech community's state-of-compliance
with the Conflict
of Interest policy and procedures;
- prepare recommendations concerning the modification of policy and procedures pertaining
of Interest at Michigan Tech;
- review, in a timely fashion, all cases of Category IV activities, even those in which
the Coordinator and
a member have reached a satisfactory agreement. In those cases connected to Category IV activities
where members and the Coordinator cannot agree upon the steps that will best ameliorate Conflicts
of Interest related to such a case, the Committee shall suggest steps to resolve the impasse. Either
party may request the involvement of this Committee;
- resolve, in a timely fashion, cases connected to proposals where members and the Coordinator
cannot agree upon the steps that will best ameliorate Conflicts of Interest; the Committee must
suggest steps to resolve an impasse. Either party may request the involvement of this Committee.
7.3.3 If the Committee, in considering cases of the last two types, finds that a significant
Conflict of Interest
exists, it will recommend to the Provost and Senior Vice President for Academic and Student Affairs that a
member take actions to ameliorate or alleviate the Conflict of Interest. These actions may include, without
- requiring public disclosure of significant financial interests;
- modification of the research proposal or entrepreneurial activity;
- monitoring of the research by outside or independent reviewers;
- disqualifying an investigator or investigators from participation in that portion
of the sponsored
research that is affected by the outside financial interest;
- requiring the investigator(s) to step aside from direct management of the outside
retaining financial interests;
- divestiture of significant financial interests;
- severance of relationships that create conflicts;
- requiring a faculty member of staff to step aside as the advisor or supervisor of
specific staff or
- discharge from Michigan Tech (see section 7.3.7).
This list is not exclusive and there may be other possible actions adopted to ameliorate
or alleviate the
Conflict of Interest.
7.3.4 In instances where a satisfactory resolution of Conflicts of Interest still cannot
be achieved through this
procedure, the Coordinator will contact relevant funding agencies to inform them of the circumstances
surrounding such cases. The Coordinator will notify Research and Sponsored Programs before contacting
these agencies. This step must be taken only at the conclusion of Michigan Tech's internal review process.
In the interest of maintaining confidentiality, principal investigators and other members must not contact
sponsors about such cases until after the Coordinator has done so.
7.4 Violations of MTU Conflict of Interest Procedures
7.4.1 All members, at the time they begin their connection with Michigan Tech, shall be
given copies of
these procedures. Michigan Tech may provide continuing education about these procedures but it is the
responsibility of each member to know their obligations.
7.4.2 Michigan Tech's Conflict of Interest procedures place significant trust and responsibility
members, who are expected to make full and open disclosure of Conflicts of Interest. Violation of this trust is
an especially serious failure of professional conduct. Michigan Tech has the authority to take action against
individuals who violate these procedures, up to and including discharge. Michigan Tech approval to
undertake particular projects, including sponsored research, consulting, and outside professional activities
that create Conflicts of Interest may be withdrawn immediately in cases where individual members fail to
fully disclose or otherwise misrepresent significant financial interests. Similarly, failure to cooperate with
Michigan Tech officials responsible for reviews of Conflict of Interest disclosure will prevent Michigan Tech
approval and sending of outside research and project proposals to potential sponsors.
7.4.3 When a violation of Michigan Tech policy is alleged (see section 7.2.3), a thorough
and timely process
shall take place within Michigan Tech to provide adequate opportunity for the Committee to reach valid
conclusions. It is imperative that the procedures described in this document be followed and protection be
afforded to the rights and reputation of both accuser and accused, those investigating the allegations, any
sponsoring agency, and Michigan Tech. All parties shall be responsible for maintaining the confidentiality of
the Committee proceedings and of all evidence developed in the proceedings to the extent allowed by law.
All proceedings shall be in accordance with applicable rules and obligations of Michigan Tech. Only
substantiated findings of violation of these procedures, as determined by either the Provost and Senior Vice
President for Academic and Student Affairs or the Michigan Tech President, will be part of the personnel
7.4.4 Allegations of violations of these procedures shall be directed to the Coordinator.
If the activities fall
under Categories I or II, the Coordinator shall refer the matter to the individual's immediate supervisor so
that Conflicts of Interest may be examined in the normal fashion. The same shall apply to activities under
Category III, with the exception of sponsored research activities. If the allegations allege violations of policy
involving sponsored research activities, or about Category IV and V activities, the Coordinator shall notify
the individual so accused, and gather basic information. The Coordinator will then present this material to
the Committee within fourteen (14) working days. The accused shall have opportunity to respond and
present information to the Committee. All evidence produced by the member shall be reviewed and secured
by the Committee. The Committee shall determine whether grounds for an investigation of a violation exist,
or whether the accusations are without merit. The Committee shall notify the accused and the Provost and
Senior Vice President for Academic and Student Affairs of its finding.
7.4.5 If the Committee determines that grounds for an investigation exist, the Provost
and Senior Vice
President for Academic and Student Affairs may accept or reject that finding. If accepted, an additional
three-person investigating Committee shall be designated to investigate the allegations. These individuals
shall be impartial members with sufficient expertise and dedication to conduct a thorough and equitable
investigation. These members will generally not be from the same academic unit as the accused.
Appointments will be made to this committee by agreement of the University Senate President and the
Michigan Tech President. Strict attention shall be paid to any factors that might compromise their ability to
impartially examine the allegations by those members asked to serve.
7.4.6 Private and separate sessions shall be conducted by the investigating Committee to
accuser(s), the accused, and others as determined necessary by the Committee. Sessions to obtain
testimony may be conducted either in person or by electronic means such as telephone conference calls.
The accused shall be informed of the accusations in writing from the investigating Committee and be given
the opportunity to respond and present evidence on his/her behalf during the inquiry. All evidence that is
produced shall be reviewed and secured. Necessary administrative support (e.g., clerical, gathering
information, witnesses, and record keeping) will be provided by the Provost and Senior Vice President for
Academic and Student Affairs.
7.4.7 The investigating Committee shall submit a written report of its findings, conclusions,
recommendations, together with pertinent documentation and evidence, to the Provost and Senior Vice
President for Academic and Student Affairs, the accused, the Coordinator, and the Committee within thirty
(30) working days after its formation, unless the time limit is extended by the Provost and Senior Vice
President for Academic and Student Affairs following a written request and explanation from the Committee.
If the investigating committee finds that the procedures have been violated, it shall recommend sanctions
(see also section 7.2.3) to reflect the seriousness of the violation. Distinctions shall be made between
neglect, honest oversights, or ignorance of procedures on the one hand, and willful violations on the other
hand, especially deliberate failures to fully disclose relationships that create Conflicts of Interest. Sanctions
may include but are not limited to sending a letter of reprimand, setting special conditions on outside
professional activities, research or consulting efforts, or external entrepreneurial activities, requiring special
certification or assurances of compliance, disbarment from the opportunity to conduct externally funded
research with selected funding agencies for fixed periods of time, or termination of employment. Any
termination shall occur in a manner consistent with existing applicable Michigan Tech policies on
employment practices and academic tenure. Michigan Tech may impose limitations or special reviews on
the outside professional and entrepreneurial activities of affected individuals.
7.4.8 The Provost and Senior Vice President for Academic and Student Affairs shall receive
investigating Committee's report and shall respond within fourteen (14) working days, accepting, modifying,
or rejecting its findings. The Provost and Senior Vice President for Academic and Student Affairs shall
submit his/her decision in writing to the accused, the investigating committee and the Committee, the
Coordinator, the appropriate dean or unit director, and the Michigan Tech President. Individuals have a right
to appeal decisions to the Michigan Tech President, making such an appeal within fourteen (14) working
days. The President shall appoint an appeals committee of at least three impartial members, at least two of
whom were not members of previous committees hearing this appeal, and who are not party to the conflict.
The committee shall report its findings and recommendations to the President within twenty-one (21)
working days of being convened. The President's decision shall be submitted to the accused, all three
committees, the Coordinator, the appropriate dean or unit director, and the Provost and Senior Vice
President for Academic and Student Affairs.
7.4.9 The Coordinator shall maintain evidence, reports, and recordings involving the allegations,
investigation for five years after the submission of the final report. Where required by the rules and
procedures of sponsoring and granting agencies, the Coordinator shall inform them of the final decisions
and provide reports of investigations.
1. This document includes enforceable provisions for members. In addition, Michigan Tech will protect its interest from selfdealing advice by including appropriate language in contracts for consultants and letters of appointment for unpaid
advisers. The Coordinator and Committee will have the opportunity to review and advise Michigan Tech on the language
used in the general form of these letters and contracts.
Adopted by Senate: 9 April 2003
Approved by President: 19 May 2003
September 2015: To reflect current university titles MTU is changed to Michigan Tech and Board of Control is
changed to Board of Trustees
 Note: This definition is from the Conflict of Interest Policies section of the
National Science Foundation Grant Policy Manual
NSF 02-051, effective August 2002, available at http://www.nsf.gov/pubs/2002/nsf02151/gpm02_151.doc