UTS 189 Institutional Conflicts of Interest

Sec. 1 Purpose

To assure that Institutional Conflicts of Interest (ICOI) are identified, disclosed, and managed or eliminated in order to safeguard the primary missions of U.T. System Administration and all U.T. institutions.

Sec. 2 Applicability

This policy applies to Institutional Conflicts of Interest of, and Institutional Officials within, The University of Texas System Administration and all U.T. institutions. Individual conflicts of interest are addressed in Regents’ Rule 30104 and UTS 175 and 180.  This policy does not apply to endowment funds invested and managed by UTIMCO.

Sec. 3 Policy Required

Each U.T. institution shall adopt a policy to identify, disclose, and manage or eliminate Institutional Conflicts of Interest.

Sec. 4 ICOI Examples

a) An institution licenses intellectual property to an outside entity and holds substantial royalty or equity interests in the entity which may be affected by ongoing institution research or other institution activities;

b) Substantial gifts to the institution appear to be connected to decisions related to the institution’s primary missions in ways that may not be appropriate;

c) An institution holds substantial investments or equity interest in an outside entity that has a financial or business relationship with the institution;

d) A Significant Outside Financial Interest of any Institutional Official affects or appears to affect the decisions of the Institution;

e) An institution enters into a transaction that compromises or appears to compromise the institution’s research, teaching, service to students, patient care, outreach mission activities, or its institutional reputation.

Sec. 5 Review Committee 

Each institution should have a committee that reviews ICOIs with sufficient authority to advise on the identification, disclosure, and management or elimination of all facets of ICOIs.  In the event that a particular ICOI relates to the Significant Outside Financial Interests of an institution president, the committee should have the authority to report its recommendations directly to U. T. System Administration.  Committees should also have the authority to refer potential ICOIs directly to U. T. System Administration in any other circumstance as determined by the committee.

Sec. 6 Committee Composition

Committees that review ICOIs should be composed of members who reflect the broad training and varied interests that arise in the ICOI context.

Sec. 7 ICOI Reporting

Potential ICOIs should be forwarded for committee review as soon as they are identified.  Institutional policies should allow for the anonymous reporting of potential ICOIs. 

Sec. 8 Monitoring and Ongoing Management

Each institution should have effective processes for the management and monitoring of ICOIs.


Executive Officers – Includes, but is not limited to, the president and Chancellor, all individuals who report directly to a president or Chancellor (other than administrative support positions), and any employee who exercises broad and significant decision-making authority over key institution or System functions.

Institutional Conflicts of Interest (ICOI) – Any Significant Outside Financial Interest of the Institution or an Institutional Official that reasonably poses a risk of significant and direct influence on decisions involving the institution’s primary interests or missions (e.g., research, teaching, service to students, clinical care, and/or administration of these missions).

Institutional Official – While each institution may expand the scope of this definition, it includes at minimum, the Executive Officers of each institution and System Administration.

Significant Outside Financial Interests of the Institution – Any substantial financial interest, including:

a) Gifts from any person, business, or entity;

b) Payments from a person, business, or entity for the licensing of intellectual property; and

c) Equity and ownership interests in entities held by the institution, including equity and ownership interests resulting from technology transfer activities.

Each institution may choose to adopt more specific criteria and thresholds, suitable to the unique circumstances of their institution.