Conflicts of Interest

A conflict of interest may occur when a person uses his or her position for personal or professional gain. All members of the University of Kentucky are to avoid even the perception of any conduct that might lead others to conclude he or she is using his/her position to inappropriately further professional, private or familial interests. Common conflicts of interest are:

• Accepting gifts or incentives from vendors or organizations through one’s work with UK (GR Part XIV; UKHC Policy A01-015; UKHC Policy A01-030).
• Nepotism, showing favor to relatives or friends, especially through hiring or promotions (GR Part X; GR Part XIV).
• Self-Interest, such as a personally- or family-owned company benefitting from the relationship to the University (GR Part XIV; UKHC Policy A01-030).
• Identifying oneself as an employee of the University in the public promotion or advertising of commercial products without prior written approval (GR Part XIV).
• A romantic relationship between a superior and a subordinate (GR Part XIV; UKHC Policy A01-030).

Competing interests can make it difficult to fulfill duties impartially. When conducting or participating in any transaction, full disclosure of any real or perceived conflict with personal interests is required. If there is a potential conflict, the party must be removed from further participation. After disclosure, the University can make a judgment about the activity and ensure appropriate oversight, restrictions, or prohibitions in accord with these policies. It is important to remember that each situation is different, and many factors will need to be considered to determine whether an actual conflict of interest exists.

For the convenience of University personnel, UK Internal Audit (UKIA) has compiled this list of administrative regulations, policies and procedures related to conflicts of interest, gifts, confidentiality, and working relationships, as well as UK’s Ethical Principles and Code of Conduct and the UK Clinical Enterprise Code of Conduct Addendum.
 

 

 

Conflict of Interest ARs, Policies and Procedures

 

Title

AR 1:7
University Ethics Committee
https://www.uky.edu/regs/ar1-7

Purpose

Establishes the University Ethics Committee and provides clear direction and outlines their responsibilities.

 

 

AR 7:2
Financial Conflicts of Interest in Research
https://www.uky.edu/regs/ar7-2

Defines Significant Financial Interest and the Research Conflict of Interest Committee.

 

 

AR 7:9
Institutional Conflicts of Interest Involving Research
https://www.uky.edu/regs/ar7-9

Focuses on Research activities; discusses required disclosures for real or perceived conflicts.
Provided direction has opportunity to be applied to non-research activities.

 

 

GR Part X
Regulations Affecting Employment
https://www.uky.edu/regs/gr10

Outlines the polices affecting faculty and staff at the University, such as employment based on merit, employment of relatives, and appointment of faculty.

 

 

GR Part XIV
Ethical Principles and Code of Conduct
https://www.uky.edu/regs/sites/www.uky.edu.regs/
files/files/gr/gr14.pdf

Specifically discusses independence of judgement, free from conflicting interests and acceptance of gifts or benefits.

 

 

BPM E-1-3
Fiscal Roles and Responsibilities
https://www.uky.edu/ufs/sites/www.uky.edu.ufs
/files/bpm/E-1-3.pdf

Defines fiscal roles and responsibilities for all employees so that University operations are well-planned, controlled, and accurately reported.

 

 

E-1-4
BPM Internal Control
https://www.uky.edu/ufs/sites/www.uky.edu.ufs
/files/bpm/E-1-4.pdf

To provide reasonable assurance regarding the safeguarding of University assets and the achievement of operational, financial reporting, and compliance objectives.

 

 

UKHC Policy 01-000
Policy Development, Review, Approval and Implementation

To outline the development, review, approval, and implementation of new and revised policies at UK HealthCare.

 

 

UKHC Policy A01-005
Code of Ethics
https://www.uky.edu/legal/ethical-principles-and-code-conduct

To set forth the code of ethics applicable to the operations of UK HealthCare.

 

 

UKHC Policy A01-015
UKHC Code of Conduct Addendum
https://www.uky.edu/legal/sites/www.uky.edu.
legal/files/Clinical_Conduct_Addendum.pdf

To provide guidelines for conduct of faculty, staff, students and house officers to comply with applicable law and to avoid conflicts of interest.

 

 

UKHC Policy A01-030
Conflicts of Interest
https://ukhcvendorreg.mc.uky.edu/Packet/A01-030%20Conflicts%20of%20Interest.pdf

Provides detailed procedures regarding what to do if employees are planning to participate in an activity which may be prohibited and/or defining prohibited activities.

 

 


A01-160
UKHC Policy
Annual Disclosure of Financial Conflicts of Interest


To outline the procedure for full disclosure of financial conflicts of interest by UK HealthCare members.

 

 

AMA Code of Conduct
https://www.uky.edu/Purchasing/docs/hosp
_ama_code.pdf

Provides the guidelines for healthcare professionals to avoid the acceptance of inappropriate gifts.

 

 

PhRMA Code of Conduct  dated 2002
https://www.uky.edu/Purchasing/docs/hospphrma.pdf

Establishes the code on interactions for pharmaceutical and biotechnology companies with healthcare professionals that relate to the marketing of products


 

If you suspect a potential conflict of interest situation within your respective department, you should inform the Office of Legal Counsel. If you have reason to believe that any of the above situations is or has taken place, please contact UKIA immediately in one of the following ways: