Further Guidance

All faculty and any other employee (regardless of job title) or student responsible for the purpose, design, conduct or reporting of research on campus, is required to disclose significant financial and personal interests and external professional activities. Explore the tables below for further guidance on disclosure obligations relating to external entities, consulting and outside work and foreign activities.

The Conflicts of Interest & Commitment (COIC) Office can be contacted by phone at (303) 492-3024 or via email at coi@colorado.edu. For additional information, please visit the COIC homepage.

Consulting & Outside Work

If YOU ...	YOU SHOULD ...	RIO INVOLVEMENT / CONTACT
…engage in any consulting or other outside work, then… “Consulting and other outside work” refers to any service that is: related to your professional expertise in your university position, provided to an external entity, for remuneration (monetary) or other compensation greater than $5,000 from a single entity over the past 12 months, including but not limited to advising; conducting research or analysis; writing reports; delivering presentations or training; contributing to or managing projects; designing, developing or producing products or services; providing clinical services.	disclose the entity to which you provided the service in your annual or updated DEPA. update your DEPA within 30 days of a status change as necessary. disclose to your supervising authority. refrain from the use of University resources, including facilities, equipment, employees, and students, without prior approval. certify that you have department approval for consulting (up to 1/6^th time) by completing the Application for Approval of Consulting and Other Outside Work. include the Standard Addendum for Consulting and Third Party Employment into external agreements in order to avoid conflict with the University’s Intellectual Property (IP) policy.	The Office of Conflicts of Interest & Commitment (COIC) can be contacted by phone at (303) 492-3024 or via email at coi@colorado.edu. COIC reviews and screens relationships disclosed via the DEPA. COIC has been engaged to confirm the management of any actual and/or potential conflict. For more information, please visit Forms, Checklists, Contacts & Links. For more information, please visit the Policies and Documents section of the Venture Partners website.
…are a current graduate student, research assistant, etc.), then…	consider the following: Level of effort – confirm that total effort does not exceed 100% of available time and that the RA portion is appropriate. Intellectual engagement. disclose the entity to which you provided the service in your annual or updated DEPA. update your DEPA within 30 days of a status change as necessary.	The academic department and advisor will need to approve the level of RA appointment when outside work/consulting is being considered. COIC can be contacted by phone at (303) 492-3024 or via email at coi@colorado.edu.

If YOU ...

YOU SHOULD ...

RIO INVOLVEMENT / CONTACT

…engage in any consulting or other outside work, then…

“Consulting and other outside work” refers to any service that is:

related to your professional expertise in your university position,
provided to an external entity,
for remuneration (monetary) or other compensation greater than $5,000 from a single entity over the past 12 months,
including but not limited to advising; conducting research or analysis; writing reports; delivering presentations or training; contributing to or managing projects; designing, developing or producing products or services; providing clinical services.

disclose the entity to which you provided the service in your annual or updated DEPA.
update your DEPA within 30 days of a status change as necessary.
disclose to your supervising authority.
refrain from the use of University resources, including facilities, equipment, employees, and students, without prior approval.
certify that you have department approval for consulting (up to 1/6^th time) by completing the Application for Approval of Consulting and Other Outside Work.
include the Standard Addendum for Consulting and Third Party Employment into external agreements in order to avoid conflict with the University’s Intellectual Property (IP) policy.

The Office of Conflicts of Interest & Commitment (COIC) can be contacted by phone at (303) 492-3024 or via email at coi@colorado.edu.

COIC reviews and screens relationships disclosed via the DEPA.
COIC has been engaged to confirm the management of any actual and/or potential conflict.

For more information, please visit Forms, Checklists, Contacts & Links.

For more information, please visit the Policies and Documents section of the Venture Partners website.

…are a current graduate student, research assistant, etc.), then…

consider the following:
- Level of effort – confirm that total effort does not exceed 100% of available time and that the RA portion is appropriate.
- Intellectual engagement.
disclose the entity to which you provided the service in your annual or updated DEPA.
update your DEPA within 30 days of a status change as necessary.

The academic department and advisor will need to approve the level of RA appointment when outside work/consulting is being considered.

COIC can be contacted by phone at (303) 492-3024 or via email at coi@colorado.edu.

External Entities

IF YOU ...	YOU SHOULD ...	RIO INVOLVEMENT / CONTACT
… (or your spouse and/or dependent children) have any (planned) external affiliations, activities, and/or interests with any domestic or foreign entities, organizations or institutions that are related (or reasonably appear to be related) to your Institutional Responsibilities at CU Boulder, including but not limited to: Ownership interests in the entities (e.g. equity, stock or stock options); Monetary or non-monetary Value received from the entities or activities including any salary; consulting fees; speaking engagement fees or reimbursements; payments for services; honorary titles; free or subsidized use of space/offices/labs, equipment, or support services including visiting researchers or other personnel; intellectual property rights or royalties; or reimbursed/sponsored travel or other payments; Research collaborations with an entity, organization, and/or institution other than a U.S. institution of higher education from which you received monetary or non-monetary value (free or subsidized space, laboratories, equipment or materials; other in-kind contributions such as support services and visiting researchers or personnel) All foreign research collaborations; Foreign talent recruitment program participation; and/or Obligations to the entities or arising from the activities (e.g., teaching or research appointments; invitations or appointments to consult in foreign talent recruitment programs; transfer of intellectual property); THEN ...	... disclose the finalized activity in your annual Disclosure of External Professional Activities (DEPA) Form. ... update your DEPA Form within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority (e.g., Department Chair or Institute Director) for the external affiliation, activity or interest: For tenured/tenure-track faculty, complete: Application for Approval of Regular and Periodic Consulting Activities. For all University employees (including but not limited to research faculty) other than tenured/tenure-track faculty, complete: Request to Engage in Outside Employment. ... refrain from using University facilities/space to privately benefit you or an Entity with whom you have a Significant Interest, unless you have first disclosed the Significant Interest and obtained written approval from your Supervising Authority and a written lease agreement from university Real Estate Services. ��&�Բ��;“Significant Interest” is a Financial Interest or other personal interest received from or held in an entity outside of the university that reasonably appears to be related to the Discloser’s Institutional Responsibilities (Significant Interest includes Significant Financial Interest). … refrain from diverting contracts/opportunities or using other University resources to privately benefit you or an Entity unless you have first disclosed the Significant Interest and obtained approval from your Supervising Authority and a written agreement from an authorized and disinterested University official (see ). ... complete the Procurement Service Center’s prior to making any purchase or requesting any purchase that may involve an actual, potential and/or perceived conflict (e.g. that may privately benefit you, your immediate family or an Entity); provide the completed form, along with information regarding the Significant Interest to your Supervising Authority; and use University procurement and purchasing services, processes and pricing only for the benefit of the University. ... include Venture Partners’ Standard Addendum for Consulting and Third Party Employment into any external consulting or employment agreements in order to avoid conflict with the University’s Intellectual Property Policy.	Contact Office of Conflicts of Interest & Commitment (“COIC”) via email at coi@colorado.edu or by phone at (303) 492-3024. COIC should be contacted prior to beginning any new engagements in order to assess the need for any actual and/or perceived conflicts. COIC will review and screen Significant Interests disclosed via the DEPA Form, and, if applicable, a Management Plan will go into effect in order to manage the Conflict of Interest and/or to prevent a Significant (Financial) Interest from ripening into a Conflict of Interest. Contact your Office of Contracts & Grants (“OCG”) Proposal Analyst. Contact Venture Partners via email at vpcontact@colorado.edu, for questions and/or assistance relating to inventions, intellectual property and formation of new startup companies. Contact Office of Export Controls (“OEC”) via email at exportcontrolshelp@colorado.edu. For more information, please visit Academic and Researcher Conflicts of Interest and Commitment Policy & Standards via the COIC webpage. For more information, please visit Frequently Asked Questions (FAQs) via the COIC website. For more information, please visit Forms, Checklists, Contacts & Links via the COIC website.
... have planned consulting activities with any entities, organizations or institutions that exist internationally, THEN ...	... contact Office of Export Controls for guidance on export control regulatory compliance.	Contact OEC via email at exportcontrolshelp@colorado.edu.

IF YOU ...

YOU SHOULD ...

RIO INVOLVEMENT / CONTACT

… (or your spouse and/or dependent children) have any (planned) external affiliations, activities, and/or interests with any domestic or foreign entities, organizations or institutions that are related (or reasonably appear to be related) to your Institutional Responsibilities at CU Boulder, including but not limited to:

Ownership interests in the entities (e.g. equity, stock or stock options);
Monetary or non-monetary Value received from the entities or activities including any salary; consulting fees; speaking engagement fees or reimbursements; payments for services; honorary titles; free or subsidized use of space/offices/labs, equipment, or support services including visiting researchers or other personnel; intellectual property rights or royalties; or reimbursed/sponsored travel or other payments;
Research collaborations with an entity, organization, and/or institution other than a U.S. institution of higher education from which you received monetary or non-monetary value (free or subsidized space, laboratories, equipment or materials; other in-kind contributions such as support services and visiting researchers or personnel)
All foreign research collaborations;
Foreign talent recruitment program participation; and/or
Obligations to the entities or arising from the activities (e.g., teaching or research appointments; invitations or appointments to consult in foreign talent recruitment programs; transfer of intellectual property);

THEN ...

... disclose the finalized activity in your annual Disclosure of External Professional Activities (DEPA) Form.
... update your DEPA Form within 30 days of a status change.
... disclose to and receive approval from your Supervising Authority (e.g., Department Chair or Institute Director) for the external affiliation, activity or interest:
- For tenured/tenure-track faculty, complete: Application for Approval of Regular and Periodic Consulting Activities.
- For all University employees (including but not limited to research faculty) other than tenured/tenure-track faculty, complete: Request to Engage in Outside Employment.
... refrain from using University facilities/space to privately benefit you or an Entity with whom you have a Significant Interest, unless you have first disclosed the Significant Interest and obtained written approval from your Supervising Authority and a written lease agreement from university Real Estate Services.
- ��&�Բ��;“Significant Interest” is a Financial Interest or other personal interest received from or held in an entity outside of the university that reasonably appears to be related to the Discloser’s Institutional Responsibilities (Significant Interest includes Significant Financial Interest).
… refrain from diverting contracts/opportunities or using other University resources to privately benefit you or an Entity unless you have first disclosed the Significant Interest and obtained approval from your Supervising Authority and a written agreement from an authorized and disinterested University official (see ).
... complete the Procurement Service Center’s prior to making any purchase or requesting any purchase that may involve an actual, potential and/or perceived conflict (e.g. that may privately benefit you, your immediate family or an Entity); provide the completed form, along with information regarding the Significant Interest to your Supervising Authority; and use University procurement and purchasing services, processes and pricing only for the benefit of the University.
... include Venture Partners’ Standard Addendum for Consulting and Third Party Employment into any external consulting or employment agreements in order to avoid conflict with the University’s Intellectual Property Policy.

Contact Office of Conflicts of Interest & Commitment (“COIC”) via email at coi@colorado.edu or by phone at (303) 492-3024.
- COIC should be contacted prior to beginning any new engagements in order to assess the need for any actual and/or perceived conflicts.
- COIC will review and screen Significant Interests disclosed via the DEPA Form, and, if applicable, a Management Plan will go into effect in order to manage the Conflict of Interest and/or to prevent a Significant (Financial) Interest from ripening into a Conflict of Interest.
Contact your Office of Contracts & Grants (“OCG”) Proposal Analyst.
Contact Venture Partners via email at vpcontact@colorado.edu, for questions and/or assistance relating to inventions, intellectual property and formation of new startup companies.
Contact Office of Export Controls (“OEC”) via email at exportcontrolshelp@colorado.edu.
For more information, please visit Academic and Researcher Conflicts of Interest and Commitment Policy & Standards via the COIC webpage.
For more information, please visit Frequently Asked Questions (FAQs) via the COIC website.
- For more information, please visit Forms, Checklists, Contacts & Links via the COIC website.

... have planned consulting activities with any entities, organizations or institutions that exist internationally, THEN ...

... contact Office of Export Controls for guidance on export control regulatory compliance.

Contact OEC via email at exportcontrolshelp@colorado.edu.

Foreign Activities & Interests

For additional information, please visit the COIC webpage and the Office of Contracts & Grants (OCG) webpage on disclosures.

IF YOU ...	YOU SHOULD ...	RIO INVOLVEMENT / CONTACT
… have any external affiliations, activities, and/or interests with any foreign entities, organizations, or institutions that are related, or reasonably appears to be related, to your Institutional Responsibilities at CU Boulder, including, but not limited to: Ownership interests in the entities (e.g. equity, stock or stock options); Monetary or non-monetary value received from the entities or activities, including research collaborations with the intent to publish (e.g. any salary; consulting fees; speaking engagement fees or reimbursements; payments for services; honorary titles; free or subsidized use of space/offices/labs, equipment, or support services including visiting researchers or other personnel; intellectual property rights or royalties; or reimbursed/sponsored travel or other payments); Obligations to the entities or arising from the activities (e.g., teaching or research appointments; invitations or appointments to consult in foreign talent recruitment programs; transfer of intellectual property); THEN ...	... read CU Boulder’s Guidelines for Foreign Collaborations. ... disclose the activity in your annual Disclosure of External Professional Activities ("DEPA") Form. ... update your DEPA Form within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority, (e.g. Department Chair or Institute Director). For tenured/tenure-track faculty, complete: Application for Approval of Regular and Periodic Consulting Activities. For all University employees (including but not limited to research faculty) other than tenured/tenure-track faculty, complete: Request to Engage in Outside Employment. ... follow the University of Colorado's and any Department policies and procedures related to dual appointments at other institutions. ... refrain from using University facilities/space to privately benefit you or an Entity with whom you have a Significant Interest, unless you have first disclosed the Significant Interest and obtained written approval from your Supervising Authority and a written lease agreement from university Real Estate Services. ... refrain from diverting contracts/opportunities or using other University resources to privately benefit you or an Entity unless you have first disclosed the Significant Interest and obtained approval from your Supervisor and a written agreement from an authorized and disinterested University official. ... notify your Office of Contracts and Grants (“OCG”) Proposal Analyst. ... disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor. ... disclose the relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors as well as annual reports as required by the sponsor. ... contact the Office of Export Controls (“OEC”) for review to ensure the associated activity does not violate U.S. open research standards, illicitly further technology in other countries using U.S. federal funding, etc.	Contact the Office of Conflicts of Interest & Commitment ("COIC") via email at coi@colorado.edu or by phone at (303) 492-3024. COIC should be contacted prior to beginning any new engagements in order to assess the need for any actual and/or perceived conflicts. COIC will review and screen Significant Interests disclosed via the DEPA Form, and, if applicable, a Management Plan will go into effect in order to manage the Conflict of Interest and/or to prevent a Significant (Financial) Interest from ripening into a Conflict of Interest. Contact the Office of Export Controls ("OEC") via email at exportcontrolshelp@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage. Contact Venture Partners via email at vpcontact@colorado.edu. For more information, please visit the following COIC webpages: Academic and Researcher Conflicts of Interest and Commitment Policy & Standards Frequently Asked Questions (FAQs) Forms, Checklists, Contacts & Links
... have been invited to participate or are currently participating in a foreign talent recruitment program, THEN ...	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA Form within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority. ... follow the University of Colorado’s and any Department policies and procedures related to dual appointments at other institutions. ... notify your OCG Proposal Analyst. ... disclose the relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors. ... decline to participate if you have a contract to work with Huawei or a subsidiary of (currently, CU Boulder willin a Department of Energy (DoE) national lab. ... contact OEC for review to ensure the associated activity does not violate U.S. open research standards, illicitly further technology in other countries using U.S. federal funding, etc.	Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. Contact Venture Partners via email at vpcontact@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage.
… have been invited to work with Huawei or a subsidiary of Huawei, *THEN*&�Բ��;…	... disclose to your Supervising Authority. ... decline to work with Huawei or a subsidiary of (currently, the University will not accept funding from Huawei or subsidiaries of).	The Research & Innovation Office (“RIO”) keeps up-to-date on any developments in federal guidelines and regulations regarding debarment of foreign sponsors.
… have travel reimbursed or sponsored by a foreign entity, individual, or government, THEN …	... disclose the activity in your annual DEPA Form. ... update your DEPA Form within 30 days of a status change. ... disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor. … contact OEC to discuss export control-related concerns for international travel. ... comply with CU Boulder travel processes and policies (including any travel policies your Department/Institute may have); submit the trip through Concur; and, for international travel, complete an international export control travel form.	Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. OEC provides essential information regarding international travel that should be reviewed prior to travel. OEC has laptops available for researchers to borrow for CU Boulder-related international travel. For more information, please visit the International Travel section of the Export Controls webpage. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage.
… have a foreign entity propose an institutional partnership with CU Boulder and/or a consulting relationship with you, THEN …	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority. ... contact your OCG Proposal Analyst. … disclose to your sponsor(s), as required by the terms and conditions of your award. ... disclose the proposed relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors.	RIO works closely with the Global Engagement Office to support international activities that are critical to the CU Boulder mission. Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage. Contact Venture Partners via email at vpcontact@colorado.edu.
… have an active or proposed position, have been provided funding, or have a foreign research collaborations (funded or not) with a foreign institution, THEN …	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA Form within 30 days of a status change. ... follow the University of Colorado's and any Department policies and procedures related to dual appointments at other institutions. ... contact OEC to discuss export control concerns. ... disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor. ... disclose the (proposed) relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors.	Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage.
… have any external affiliations, activities and/or interests with any foreign entities, organizations or institutions that are related, or reasonably appear to be related, to your Institutional Responsibilities at CU Boulder AND have funding from the Department of Defense (DoD) or Department of Energy (DoE), THEN …	... disclose the activity in your annual DEPA Form. ... update your DEPA Form within 30 days of a status change. ... contact OCG prior to starting any international collaboration (related to the research or otherwise).	Contact COIC via email at coi@colorado.edu. Contact your OCG Proposal Analyst. DoD and DoE have specific clauses that may limit international collaboration.
… have ownership interest in a foreign company, THEN&�Բ��;…	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA within 30 days of a status change. ... disclose the relationship in biosketch and current and pending documents on proposals to federal sponsors (if applicable) and in annual reports as required by the sponsor.	Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage.
… plan to host or do host a visiting scholar, student, tour group or other individual from a foreign entity, THEN …	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority. ... contact OEC to review intended locations to be visited, verify if any restrictions apply and vet individuals who will be visiting.	Contact COIC via email at coi@colorado.edu. Contact OEC via email at exportcontrolshelp@colorado.edu. Refer to the Office of Contracts and Grants website for disclosure information, tools and contacts, such as: Disclosing Other Support webpage. For more information, please visit the Foreign Visitors section of the Export Controls webpage.
… anticipate a project that is classified and/or involves controlled unclassified information ("CUI"), THEN …	... disclose the finalized activity in your annual DEPA Form. ... update your DEPA within 30 days of a status change. ... disclose to and receive approval from your Supervising Authority. ... contact the OCG Research Security team. ... contact the CU Boulder Research Cyber Security Program for CUI research.	Contact COIC via email at coi@colorado.edu. Contact OCG Research Security team via email at cufso@colorado.edu. Contact CU Boulder Research Cyber Security Program via email at scott.maize@colorado.edu.

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