Adopted By: Institutional Conflict of Interest Committee November 2, 2011
Revised: January 20, 2012
Revised: February 1, 2016

1. The Office of the Chancellor provides a list of senior officials required to disclose (i.e., the Chancellor, Vice Chancellors, the Provost, Vice Provosts, and Deans), and these officials shall be responsible for identifying other officials within their areas of responsibility whom possess discretionary authority to allocate resources related to the University enterprise. The full list of those required shall be collected by the Chancellor’s Office, or his/her designee.

2. These individuals are provided an ICOI disclosure form. For those who have to file it, the Wisconsin Statements of Economic Interests can be used for this process. The request includes a completion due date.

3. The COI Program Office collects the disclosures and submits them to the ICOI committee for review.

4. The ICOI Committee/COI Program Office staff prepares a report/summary in consultation with the Associate Vice Chancellor for Research Policy and Integrity.

   The ICOI Committee reviews each disclosed financial interest for the potential to appear to affect any of the following: objectivity, independence and integrity of research; safety of human subjects; objectivity, independence and integrity of teaching; objectivity and independence of outreach activities; appropriate use and allocation of university resources; and objectivity and independence in business and contracting decisions.

   For each financial interest, the committee will then determine if the financial interest has the likelihood of conflict of interest with the research, teaching, and outreach activities of the university.

5. A report/summary is sent to the Provost. The Provost, or his/her Designee, will review the recommendations of the ICOI Committee and determine a course of action consisting of one or more of the following:

   • No action required
   • Disclosures of the financial interest to affected persons in circumstances related to their University responsibilities
   • Oversight of decision-making or participation in an activity by an independent third party
   • Elimination of the financial interest or reduction to a level below the de minimis threshold
   • Recusal from decision-making or participation in an activity that would directly or indirectly involve the person's financial interest
   • Other measures determined by the Provost

   The Provost's determination will be conveyed in a letter to the affected University Official. The Provost, or his/her designee, will meet with individuals and review management plans annually.

6. The ICOI review will be an annual process coincidental with review of the individual COI Outside Activity Report (OAR). As with the OAR, individuals identified for the ICOI disclosures are required to update during the year as emerging circumstances warrant.