Non-Compliance with UO Policy and Management Plans

UO employees and sponsored researchers are responsible for fully complying with the UO's Conflict of Interest, Conflict of Commitment, and Outside Activities Policy, the UO's Financial Conflict of Interest in Research Policy, sponsor regulations, and Oregon State ethics laws.

Compliance includes disclosing outside activities and interests and following management plans. Signatories on management plans, such as supervisors and unit heads, play a vital role in monitoring employees' compliance with UO policies and with management plans.

Non-compliance may subject the employee to discipline, up to and including termination, consistent with applicable UO policies and collective bargaining agreements. Non-compliance can be reported to the UO Ethics hotline.

Report a Non-compliance Concern

Non-compliance: Conflict of Interest, Conflict of Commitment, and Outside Activities Policy

When notified of an allegation of non-compliance with the COI/COC Policy, our senior-level staff determine within 60 days whether an employee is indeed non-compliant. If the determination is that non-compliance has occurred, staff complete a review, which may include:

  • A request to the employee to submit or update their disclosure
  • Outreach to the employee's supervisor and/or unit head to determine whether or to what extent the outside activity may have impacted the employee's UO job duties, financial gain, or avoidance of financial loss

Reviews are completed within 120 days of determining non-compliance. The Associate Director of Conflicts of Interest and Export Controls works with the employee, their supervisor, and senior leadership as needed to remedy the non-compliance and develop action steps specific to each case. Employees may appeal a determination of non-compliance.

Non-compliance: Financial Conflicts of Interest in Research Policy

When notified of an allegation of non-compliance with the FCOI Policy, our senior-level staff determine within 60 days whether an investigator is indeed non-compliant. If the determination is that non-compliance has occurred, staff then complete a retrospective review. The retrospective review may include:

  • A request to the investigator to submit or update their disclosure
  • Outreach to the investigator's principal investigator (PI), supervisor, and/or unit head to determine to what extent, if any, bias is found in the design, conduct, or reporting of research during the time period of non-compliance.

As required by federal sponsor regulations and UO's FCOI Policy, the retrospective review must be completed within 120 days of identifying that non-compliance occurred. The Conflict of Interest in Research Committee (COIRC) makes a final determination of non-compliance and makes a recommendation on action steps to be undertaken by the investigator. The investigator will be notified of the determination and the required action steps, and investigators may appeal a determination of non-compliance.

If the retrospective review identifies bias has occurred as a result of the non-compliance and the COIRC agrees that is the case, our senior-level staff complete a mitigation report. The mitigation report:

  • Specifies in what ways the sponsored activity was bias because of the non-compliance
  • Outlines a plan of action to eliminate or mitigate the effect of the bias

Retrospective reviews and mitigation reports may be shared with the investigator, the PI, unit heads, and/or sponsoring agency as required by federal sponsor regulations and the UO's FCOI Policy.