This policy is provided to help the university examine circumstances surrounding gifts, grants, and personal holdings, and manage (through disclosure, separation of responsibilities, or other appropriate requirements) any actual or apparent conflicts of interest that may result.
The university operates through the actions of university officials, individuals with administrative authority and responsibility. This policy governs institutional conflicts of interest at the university and applies to university officials.
The Wisconsin Alumni Research Foundation (WARF), the University of Wisconsin Medical Foundation (UWMF), the University of Wisconsin Hospital and Clinics (UWHC), the Morgridge Research Institute, WiCell, and the University of Wisconsin Foundation (UWF) are organizations that are separate and independent from the university. Because of the independent nature of these organizations, unless specifically addressed in this policy, the actions of these organizations are sufficiently outside the control of the university or a university official that no ICOI evaluation is needed.
This policy does not govern situations in which individuals who are not university officials might realize financial gain from the conduct of research or performance of other responsibilities at the university; the university’s Conflict of Interest Committee, using existing policies and procedures, adequately identifies such situations and independently manages their associated risks to scientific objectivity and proper treatment of human subjects.
As UW–Madison collaborates with an ever-expanding network of affiliated organizations to apply the fruits of research and scholarship to benefit society, the potential exists for institutional conflicts of interest. The following policy signals our commitment to the disclosure, identification, and management of institutional conflicts of interest.
The following principles will guide the university in addressing institutional conflicts of interest:
The Board of Regents of the University of Wisconsin System, the UWF, and the university have established policies regarding the acceptance of extramural support, including gifts, grants, contracts, and cooperative agreements. These policies apply to university officials as defined here and are summarized below.
All gifts and grants to the university must be accepted in conformance with the following policies:
The following circumstances should be evaluated when considering decisions to commit substantial resources of the university or when university officials are responsible for the direction/control of significant university activities:
The chancellor, or the chancellor's designee, has the authority to implement disclosure and review processes, to oversee procedures to address institutional conflicts of interest, and to develop and monitor plans for managing, reducing, or eliminating institutional conflicts of interest involving:
In these instances of conflicts of interest, the associate vice chancellor for research policy and integrity will consult with the chancellor.
In instances where the chancellor may have an institutional conflict of interest, the chancellor must recuse themself and defer to the president of the University of Wisconsin System, who will review, create, and approve management plans in consultation with the associate vice chancellor for research policy and integrity who will consult with the chancellor.
University officials and other individuals covered under this policy will, upon appointment and annually thereafter, file a financial disclosure statement with the Office of the Chancellor disclosing significant financial interests. For those required to file it, a Wisconsin Statement of Economic Interests is sufficient to fulfill this disclosure requirement. Those not required to file a Wisconsin Statement of Economic Interests will receive a university form designed for this process.
University officials and other individuals covered under this policy will disclose to campus Institutional Review Boards (IRBs) any conflicts of interest they may have, as well as any management plans or exceptions to management issued by the Conflict of Interest Committee, with regard to their human subjects research activities reviewed by the campus IRBs. Such disclosures occur by answering the standard conflict of interest questions in IRB applications. (See Financial Conflicts of Interest in Human Subjects Research: Policies and Procedures, Appendix 2. Procedures, (a) Reporting, (ii) To IRBs).
University officials and other individuals covered under this policy will provide a revised financial disclosure statement through appropriate outside activities reporting processes within 30 days of acquiring any new significant financial interests.
Related document: Institutional Conflict of Interest (ICOI) Procedures
Significant financial interests do not include the following: