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Guidance for Answering Staff COI Questionnaire

Question #1  |  Question #2  |  Question #3  |  Question #4  |  Question #5  |  Question #6
Sponsored Research Questions  |  Other Documentation & Resources

Question 1

During the previous calendar year, were you or was any member of your immediate family a director, officer, partner, employee, an independent contractor of, an agent of, or a consultant to any entity that does business with 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.  Disclosure of such a relationship helps to assure objectivity in decision-making, and does not necessarily mean the services need to stop.

DO DISCLOSE relationships/activities with entities that relate to Northwestern activities or that conduct business with Northwestern. For example:

  • 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

During the previous calendar year, did you or any member of your immediate family have direct financial interests (such as ownership or equity interests), or indirect financial interests (such as reciprocal relationships or arrangements) with any entity that does business with Northwestern University?

*Do not disclose equity interests in publicly-traded entities or interests related to retirement accounts or mutual funds.

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.  Disclosure of such a relationship helps to assure objectivity in decision-making, and does not necessarily mean the services need to stop.

DO DISCLOSE financial interests in/arrangements with entities that relate to Northwestern activities or that conduct business with Northwestern. Listed below are examples of appropriate responses to this question:

  • I own a business, which supplies promotional items and apparel to Chicagoland companies, colleges, and universities.
  • 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.
  • My start-up company provides lab equipment to various departments at Northwestern.

DO NOT DISCLOSE financial interests/arrangements that do not relate in any way to Northwestern activities or that do not do business with Northwestern (e.g., you are a research assistant in molecular biosciences and you also own an herbal garden business, and that business does not provide goods or services to Northwestern) and DO NOT DISCLOSE interests in publicly-traded companies (e.g., your family has stock in Computer Discount Warehouse (CDW Corporation), even if they are a University vendor.

Question 3

During the previous calendar year, did you or did anyone from your immediate family receive any gift (other than promotional items or an occasional business meal) or receive unusual or extraordinary hospitality from 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.

DO DISCLOSE gifts that are greater than nominal (i.e., approximately $75 in value or greater) and DO DISCLOSE unusual hospitality (i.e., anything more than an occasional business meal).  For example:

  • [Company name] hosted me at an all-day golf outing. The value of the golf an meals was [approximate value]. A [company name] representative was present at the golf outing.
  • Within the past year, [company name] has hosted me at a professional basketball game on two occasions. The value of the tickets were [approximate value]. A [company name] representative was present at each basketball game with me.
  • [Company name] sent me a holiday ham worth approximately [approximate value]. I handled the gift in this way [explain how you handled the individual gift (e.g., you donated it or returned it) and who was notified (e.g., immediate supervisor, NUCOI, etc.)].

DO NOT DISCLOSE promostional items, occasional business meals, or nominal gifts (e.g., flowers, baked goods, candy, pens, notebooks, or similar trivial items that wer shared rather than received as an individual gift).

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

During the previous calendar year, did you (either personally or in your role at NU) or did anyone from your immediate family give any gift (other than promotional items) or provide unusual or extraordinary hospitality to a supplier or vendor of Northwestern University?

Gifts from the University to suppliers can affect or appear to affect the objectivity of judgment with respect to both the gift giver and recipient.

DO DISCLOSE gifts provided to University vendors or supplies. Listed below are examples of appropriate responses to this question:

  • 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.

DO NOT DISCLOSE:

  • Charitable or other donations you and/or a family member may have contributed to Northwestern University.

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?

Question 5

During the previous calendar year, did you 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.

DO DISCLOSE greater than incidental use of University time and/or resources for outside activities. Listed below are examples of appropriate responses to this question:
  • I am involved in civic activities for which I use my work computer to make meeting materials and receive e-mails. I occasionally receive and make related phone calls, too.
  • I occasionally use the department 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.

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.

Question 6

During the previous calendar year, were there any other activities not already reported under the previous questions that you think might be (or might be perceived as) a conflict of interest with respect to your work at Northwestern?

*Do not disclose activities or events relative to professional association affiliated with Northwestern University or Northwestern University-authorized professional development activities or events.

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, but if you are paid or compensated in any other way for your participation or volunteer activities, it should be disclosed.

DO DISCLOSE: Anything that could potentially be perceived as influencing or detracting from your role at the University that is not covered by the previous questions.

Sponsored Research Questions

If you are also an Investigator on a sponsored research project that is subject to Northwestern's Conflict of Interest in Research policy, you will be able to view your answers to the research questions and add any additional, relevant information, which will satisfy the annual disclosure requirement for research.  For more information on answering the Sponsored Research Questions, please see the guidance provided here.