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Guidance for Answering Staff COI Questionnaire

Question #1  |  Question #2  |  Question #3  |  Question #4  |  Question #5  |  Question #6
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Question 1

Are you or is any member of your immediate family a director, officer, owner, partner, employee, an agent of, or a consultant to any firm that provides products or services to Northwestern University? If you perform services for another company, are you paid?

If yes, identify the name of the business and describe the business and the nature of your relationship to it and that of your immediate family.

If you or a family member (your spouse, child, sibling, or parent) have interests in a business providing services to the University, there is a potential conflict of interest that may be resolved by making the relationship known. This will help assure objectivity in decision-making, and does not necessarily mean the services need to stop.

Listed below are examples of how an employee might respond to Question 1:

  • My husband is a sales representative for [company name], which is an approved vendor for Northwestern University.
  • My sister works for [company name], which has provided consulting services to Northwestern.
  • I am currently a member of the board of directors at [company name], which has a long-term contract to supply Northwestern with goods / services.
  • I own a business, which supplies promotional items and apparel to Chicago land companies, colleges and universities.

If a staff member discloses a potential conflict of interest because a family member works for a company that NU does business with or the employee has a financial investment in that company, below is a follow up list of questions that may be applicable for the employee or supervisor to consider when such a possible conflict of interest is disclosed:

  • If the company is not a “preferred” vendor, did you check to see if the University already had a preferred vendor contract in place for the product or service needed?
  • Did you verify with Purchasing Resource Services that your vendor relationship doesn’t already conflict with another vendor contract or with Facilities Management in case a service contract might violate one of our union contracts?
  • If the vendor relationship is with your specific school or department, were bids requested prior to selecting the company to ensure quality and competitive pricing?
  • What were the evaluation criteria?
  • How much influence did the employee have in selecting the company?
  • Did someone other than the employee select the company?
  • Did someone else within the organization approve the decision to select the company?
  • Does someone other than the employee approve the invoice(s) for payment?
  • What is the dollar value of the product/service purchased from this company on an annual basis?
  • Does a written agreement exist and at a minimum, include insurance and indemnification clauses, if applicable? Note: standard language can be found under the link called Contractor Insurance Requirements at:

http://www.northwestern.edu/risk/insurance/contractor.html

Question 2

In the past twelve months, have you or has any member of your immediate family had a direct or indirect financial interest in any business, excluding publicly traded companies, that provides products or services to Northwestern University?

If yes, identify the name of the business and describe the business and the nature of your relationship to it and that of your immediate family.

If you or a family member (your spouse, child, sibling, or parent) is in a business providing services to the University, there is a potential conflict of interest that may be resolved by making the relationship known. This will help assure objectivity in decision-making, and does not necessarily mean the services need to stop.

Listed below are examples of how an employee might respond to Question 2:

  • I own stock in a public company (outside my Northwestern retirement plan contributions) that does business with Northwestern University.
  • My husband owns [company name], which provides design and print services to our department.
  • My wife is a freelance writer who worked with my department for five years. She still occasionally writes articles for us.

If a staff member discloses a potential conflict of interest because a family member works for a company that NU does business with or the employee has a financial investment in that company, below is a follow up list of questions that may be applicable for the employee or supervisor to consider when such a possible conflict of interest is disclosed:

  • If the company is not a “preferred” vendor, did you check to see if the University already had a preferred vendor contract in place for the product or service needed?
  • Did you verify with Purchasing Resource Services that your vendor relationship doesn’t already conflict with another vendor contract or with Facilities Management in case a service contract might violate one of our union contracts?
  • If the vendor relationship is with your specific school or department, were bids requested prior to selecting the company to ensure quality and competitive pricing?
  • What were the evaluation criteria?
  • How much influence did the employee have in selecting the company?
  • Did someone other than the employee select the company?
  • Did someone else within the organization approve the decision to select the company?
  • Does someone other than the employee approve the invoice(s) for payment?
  • What is the dollar value of the product/service purchased from this company on an annual basis?
  • Does a written agreement exist and at a minimum, include insurance and indemnification clauses, if applicable? Note: standard language can be found under the link called Contractor Insurance Requirements at:

http://www.northwestern.edu/risk/insurance/contractor.html

Question 3

At any time in the past twelve months, have you or has anyone from your immediate family received any gift (other than promotional items or an occasional meal) or unusual hospitality from a supplier or vendor of Northwestern University? If yes, note face value of gift. If tickets, how many and did the donor of the tickets attend the event with you?

Gifts received from suppliers to the University or gifts given to suppliers can affect or appear to affect the objectivity of judgment regarding that supplier. Gifts can bring with them an expectation to return a favor. If you have a doubt about an item received or given, a discussion with your supervisor can help resolve a potential conflict of interest that a gift might represent.

Listed below are examples of how an employee might respond to Question 3:

  • [Company name] has sent our department flowers as a "thank you" for having a meeting with them.
  • Within the past year, [company name] has hosted me at a professional basketball game on two occasions. The value of the tickets were [price]. A [company name] representative was present at each basketball game with me.
  • [Company name] sent me a $200 gift certificate, which I [kept or returned].

Issues to consider when responding to this COI question may include:

  • How often were gifts received and/or meals covered?
  • What was the value of these gifts and/or meals?
  • If an event, was a supplier or vendor representative present at the event?
  • Were the topics of discussion at the meal related to Northwestern University business, and was this conversation a benefit to the University?
  • Did your supervisor approve your acceptance of the gifts and/or meals?
  • Do you have any authority to select, hire or contract with this vendor, or are you only a recipient of their services?
  • Do you have any influence in the selection, hiring or contracting of this vendor for Northwestern University?

Question 4

At any time in the past twelve months, have you or has anyone from your immediate family given any gift (other than promotional items) or unusual hospitality to a supplier or vendor of Northwestern University?

Gifts received from suppliers to the University or gifts given to suppliers can affect or appear to affect the objectivity of judgment regarding that supplier. Gifts can bring with them an expectation to return a favor. If you have a doubt about an item received or given, a discussion with your supervisor can help resolve a potential conflict of interest that a gift might represent.

Listed below are examples of how an employee might respond to Question 4:

  • I provided 2 tickets for the NU football game to someone I know at [company name]. I don't think they have any ties to the University.
  • I gave 4 NU basketball tickets to the sales rep we work with at the printing company my department uses for our promotional brochures and posters.

Issues to consider when responding to this COI question may include:

  • Did your or a family member’s relationship with a vendor influence the exchange of gifts or unusual hospitality provided to the vendor?

It is not necessary to disclose whether and how much you and/or a family member might have contributed to Northwestern University.

Question 5

Are there any other personal activities of yours, not reported under the previous questions, that you think might be a conflict of interest with respect to your work at Northwestern University?

Providing other employers with the same services you provide to the University could be in conflict with University interests if the work subtracts from effort expected in your University job or if it competes with University interests. However, holding another job outside the University is not necessarily a conflict by itself. If there is any doubt, you should discuss the activity with your supervisor and resolve the doubt.

Listed below are examples of how an employee might respond to Question 5:

  • I am a member of the board of directors at [non-profit organization name] and typically every other month I leave early to attend board meetings.
  • I am a member of [name of professional association], which occasionally holds events that I attend during work time.
  • I have a second job at [company name], where I teach classes, but I do not teach at Northwestern University.

Issues to consider in relation to this question may include:

  • Generally, it is not a conflict if you participate and/or volunteer in a professional association (with advanced approval of your supervisor) that is related to your work activities and/or profession.
  • Please list the name of the organizations/associations/memberships. However, if you are paid or compensated in any other way for your participation or volunteer activities, it should be disclosed.

Question 6

Do you have occasion to use University resources (equipment, space, supplies or your paid work time other than incidental interruption) in performing paid or volunteer activity for entities other than Northwestern University or its affiliates?

Using university time or equipment or supplies for professional or civic activities related to your work or University employment is not a conflict insofar as these activities contribute to the University's interests. The amount of time or resources may be an issue requiring discussion with your supervisor to assure compatibility with performance of your job and affordability in drawing on the department's resources. Personal activities unrelated to work but using your time on the job or the department's resources require a 'yes' response and a discussion with your supervisor.

Listed below are examples of how an employee might respond to Question 6:

  • I am involved in civic activities for which I use my computer to make meeting materials and receive e-mails. I occasionally receive and make related phone calls, too.
  • I occasionally use the copier to make a small number of handouts for a youth group I volunteer with once a month. I have discussed this with my supervisor.
  • When presenting at [professional association name] meetings, I will occasionally use Northwestern University resources to prepare for my presentation.