APS #4013

ActiveUnder Review Revision

Officer Disclosure of Interests

Brief Description

Sets forth university requirements for the submission and review of an annual disclosure of outside financial interests and activities by officers and other employees designated by officers.

Policy Profile

APS Policy Title: 
Officer Disclosure of Interests
APS Number: 
Proposed Effective Date: 
July 1, 2017
Effective Date: 
July 1, 2015
Approved By: 
President Bruce D. Benson
Responsible University Officer: 
Vice President and Chief Financial Officer
Responsible Office: 
Office of University Controller
Policy Contact: 
The appropriate campus controller, who will consult with the University Controller as appropriate, will respond to questions and provide guidance regarding interpretation of this policy. Any exceptions to this policy must be approved by the University Controller.
Officer Disclosure of Interests, January 17, 2013
Last Reviewed/Updated date: 
July 1, 2015
Applies to: 
All campuses

I. Introduction

This policy implements Regent Policy 3-B, Conflict of Interest--University Staff, which requires all officers to submit an annual disclosure of outside financial interests and activities to be reviewed for possible conflicts of interest. The purpose of the policy is to identify all outside interests (not just conflict of interests) in order to:

  1. determine all potential conflict of interestsConflict of InterestSituations defined in the Administrative Policy Statement Conflict of Interest Policy in which financial or other personal considerations may compromise, or have the appearance of compromising, an employee's professional judgment in administration, management, instruction, research and other professional activities. This includes situations in which an employee might derive private gain due to her/his association with the University. have been properly mitigated;
  2. fulfill the university’s obligation to disclose related party transactions under Generally Accepted Accounting Principles (GAAP); and
  3. fulfill the university’s obligation to include certain organizations in the university’s financial reporting entityFinancial Reporting EntityAs defined by generally accepted accounting principles, the University plus all organizations that meet the following criteria: 1. organizations for which the University is financially accountable (equivalent to control by the University as an entity or its Regents or Officers); 2. a legally separate, tax-exempt organization: whose economic resources are entirely or almost entirely for the direct benefit of the University's financial reporting entity or its constituents, where the University has the ability to access (broader than control and is demonstrated by the ability not the occurrence in a given year) a majority of its economic resources, and such economic resources are Material to the University; 3. organizations for which the nature and significance is such that exclusion would be misleading to the University's financial statements; or 4. organizations closely related to or financially integrated with the University as exhibited through policies, practices or organizational documents of either entity. under GAAP.

The responsibility to report annually under this policy does not relieve officers of their obligation on a prospective basis to identify, seek guidance and mitigate conflicts of interest as they arise.

II.  Policy Statement

  1. University Controller Responsibility

    The University Controller shall establish officer disclosure requirements, which at a minimum shall include the information specified in Section II.B. The campuses may identify additional disclosure requirements at their discretion.

    The University Controller shall also develop an officer disclosure form and submission process for system officers, which the campuses may choose to adopt pursuant to Section II.C.
  2. Officer Responsibility

    Consistent with the University Controller’s disclosure requirements, all officers must disclose annually the following types of information in any case where associated compensation exceeds $5,000​:
  3. Campus Responsibilities

    Each campus is responsible for:

III.  Procedures, Forms, Guidelines and Resources

  1. Related Administrative Policy Statements (APS)
  2. Related Forms

    Disclosure forms are online. Each campus may have its own unique form.

IV.  Definitions

Italicized terms used in this Administrative Policy Statement are defined in the Policy Glossary of Terms.

V.  History

VI.  Key Words

Officer, disclose, disclosure, interests, financial, outside, activities