FAQs Regarding the Conflict of Commitment and Reportable Outside Activities Policy
Capitalized terms are defined in the policy. Please refer to the Definitions section.
- What is a Conflict of Commitment?
- What is a Reportable Outside Activity?
- Who is required to submit the Reportable Outside Activity Disclosure?
- What are some examples of exempt employees?
- If I am not sure whether I need to submit a Reportable Outside Activity Disclosure, who is the contact for clarification?
- When do I have to file the Reportable Outside Activity Disclosure?
- Where do I find the Reportable Outside Activity Disclosure?
- I completed a Reportable Outside Activity Disclosure last year. Why do I have to complete the disclosure again?
- If the circumstances of a Reportable Outside Activity change after I receive permission to engage in it, do I need to do anything?
- If I don’t file a Reportable Outside Activity Disclosure and engage in an outside activity, what are the consequences?
- How is Consulting defined?
- Does this policy prohibit me from being a paid consultant for a corporation or for-profit company?
- I am a tenured professor at Purdue, and I consult for several companies. Is there a time limitation on Consulting?
- I am co-founder of a company, but I do not have any income from this relationship yet. Is this a Reportable Outside Activity?
- As a scientist, I am asked to participate in online surveys relative to my area of expertise. I am paid a small amount of money for this activity. Is this a Conflict of Commitment?
- May I take an honorarium for giving a lecture?
- If I receive royalties or compensation for publishing works, is this a Reportable Outside Activity?
- I am a faculty member, and I am actively involved in a professional association related to my University duties. Is the work I perform for the association, including attendance at quarterly meetings, considered a Reportable Outside Activity?
- How does this policy work in relation to sabbatical?
- I am an officer of a professional association, and my participation is necessary to maintain a license required for my job. Do I have to submit a Reportable Outside Activity Disclosure for this activity?
- What if I don't agree with the conditions of a management plan?
- My Reportable Outside Activity Disclosure was denied. Can I appeal?
- I am an exempt employee, but my consulting is strictly limited to nights and weekends. Do I need to report it?
- As an academic-year employee, do I need to report activity that occurs during the summer?
- I'm a part-time employee. Do I need to report my other job?
- I am a member of a family LLC. The LLC owns our family farm and a house that is rented. Do I need to report the LLC as a Reportable Outside Activity?
- I'm a faculty member, and I engage in consulting. I have an LLC for my consulting activities. Do I need to disclose the LLC in years when I don't do any consulting?
- I'm a faculty member, and I do my consulting work through an LLC. Do I need to disclose each of the entities for whom the consulting work is performed?
- Am I able to use University facilities, equipment, and resources for an approved ROA?
- I'm a faculty member. Occasionally, I have the department administrative assistant perform clerical work during her Purdue work day for my consulting work through my LLC. Is this allowable?
Q 1. What is a Conflict of Commitment?
- A situation in which an employee's Reportable Outside Activities would likely interfere with the employee's ability to fulfill their commitment to the University, or if such employee’s responsibilities, financial interest or opportunity for personal benefit in connection with such Reportable Outside Activity would likely interfere with the employee’s professional judgment in exercising any University duty or responsibility.
- Participation in or affiliation with any non-U.S. entity/entities that pose, or appear to pose, a risk to the detriment of the University and/or to the integrity and security of related research constitutes a Conflict of Commitment. Participation in or affiliation with Foreign Talent Recruitment Programs that pose, or appear to pose, a risk to the integrity and security of related research constitutes a Conflict of Commitment. Risks to the detriment of the University include, but are not limited to, activities prohibited by law, regulation or other governmental orders.
- In determining whether a Reportable Outside Activity constitutes a Conflict of Commitment due to the time devoted or proposed to be devoted to the activity, the University will consider whether such activity is to take place during the normal weekday business and/or instructional hours of the University or when an employee is in paid or unpaid leave status.
Q 2. What is a Reportable Outside Activity?
A Reportable Outside Activity is defined as any work, advice or service for an entity other than Purdue University that may potentially result in a Conflict of Commitment.
The terms include, but are not limited to:
Other Universities and Research Institutes
- Appointment, affiliations, and/or service to any other university or research institute. Relationships of any type including responsibility for any course at, or representing oneself as a faculty member at, any other school or university. This category includes honorific titles, appointments as adjunct faculty, visiting professor, etc. Relationships of any type and responsibility are included.
- Business Ownership or Management
Participation in any business enterprise as owner, partner, officer, supervisor, manager or in any capacity with management responsibilities. Assuming an executive or management position for a third-party entity (e.g., President, Chief Scientific Officer, CEO.) - Board Service
Service as an officer, director, trustee, or public representative of a professional association, educational institution, nonprofit organization, national commission or board, or foundation. - External Research
Conducting external research that would not ordinarily be conducted as part of the Employee’s duties with the University. - Consulting
An Employee’s use of their professional capabilities and knowledge for the benefit of a third party in return for immediate or prospective gain to the Employee. This includes expert witness activity. - Advisory Council or Scientific Advisory Board
Provision of scientific expertise to an outside entity (e.g., pharmaceutical or device manufacturer). - Volunteer Activities
Volunteer work that involves a commitment of time that may interfere with the Employee’s ability to fulfill their responsibilities to the University. - Outside Employment or Service
Employment with or service to an outside entity where compensation in the form of money, services, goods or other consideration of value is received (e.g., serving as a journal editor). - Service to Non-U.S. Entities
Service or activities involving compensation from a foreign country or an agent of a foreign country—at the national, provincial, or local level—or from entities or persons based in, funded by, or affiliated with a foreign country. This includes attendance or presenting at a conference in a foreign country, participation in non-U.S. government agencies or boards, foreign granting agency review panels, advisory roles with non-U.S. universities, and Foreign Talent Recruitment Programs. Compensation may include cash, research funding, promised future benefits, complimentary travel, honorific titles, career advancement opportunities, or other forms of remuneration, whether or not formally stated.
Reportable Outside Activity and Reportable Outside Activities do not include:
- Volunteer work that does not interfere with the Employee’s ability to fulfill their responsibilities to the University (e.g., volunteer work that takes place on Saturday or Sunday or outside of the regular business or instructional hours of the University generally will not pose a Conflict of Commitment)
- Work, advice or service for Purdue Applied Research Institute (PARI)
- Hobbies or recreational activities
- Religious activities
- Preparing and publishing scholarly communications such as books, articles and other creative works unless 1) compensation in the form of money, services, goods or other consideration of value is received and/or 2) a non-U.S. entity or person is involved as publisher, co-author, co-editor, or some other role
- Peer review of manuscripts and grant proposals unless compensation in the form of money, services, goods or other consideration of value is received
- Editing of scholarly or professional publications or service on editorial boards for scholarly or professional publications unless compensation in the form of money, services, goods or other consideration of value is received
Q 3. Who is required to submit the Reportable Outside Activity Disclosure?
All Exempt Employees are required to submit ROA disclosures before engaging in the activity that is the subject of the disclosure. The term Exempt Employee is defined as an employee of Purdue, wherever located, and whether full-time or part-time, including but not limited to all executive officers, faculty and exempt staff, and graduate student employees, including those on leave of absence with or without pay, who are exempt from the requirements of the Fair Labor Standards Act.
- Nonexempt staff members (paid hourly), including police, fire, and skilled trade positions: These individuals are required to submit a disclosure before engaging in a Reportable Outside Activity that may interfere with their normal University responsibilities, that will take place during the employee’s normal work hours, or when the activity includes involvement with a Foreign Talent Recruitment Program.
Q 4. Several of the examples included in the definition of a Reportable Outside Activity are things that are expected of me by my supervisor. Do I have to submit the disclosure?
If you are a faculty or exempt staff member, yes, the disclosure must be submitted.
If you are a nonexempt staff member, you only need to submit the disclosure if the activity could potentially interfere with your University duties (see answer to question 4).
Many Reportable Outside Activities, in and of themselves, will not present a Conflict of Commitment, and your Unit Head will be able to approve the activity. But the particulars of the activity must be considered relative to any other activities you are engaged in and your responsibilities to the University.
Q 5. If I am not sure whether I need to submit a Reportable Outside Activity Disclosure, who is the contact for clarification?
You may contact the Outside Activity Officer, or the Vice President for Ethics and Compliance. Send inquiries to compliance@purdue.edu.
Q 6. When do I have to file the Reportable Outside Activity Disclosure?
- New Activities: You must file the disclosure before you engage in any new Reportable Outside Activity.
- Continuing Activities: At the beginning of each fiscal year, i.e., July 1, you must file a Reportable Outside Activity Disclosure for all activities in which you continue to participate, even if previous permission was granted.
- Changed Activities: If the scope or nature of a Reportable Outside Activity changes after permission has been granted, you must file a new disclosure before you can continue to engage in the changed activity.
Q 7. Where do I submit the Reportable Outside Activity disclosures?
Use this link to the online form.
Q 8. I completed a Reportable Outside Activity Disclosure last year. Why do I have to complete the disclosure again?
Reportable Outside Activities must be approved on an annual basis in order to ensure that a Conflict of Commitment doesn’t arise due to a change in either your other outside activities or other issues involving your responsibilities to the University.
Q 9. If the circumstances of a Reportable Outside Activity change after I receive permission to engage in it, do I need to do anything?
Yes, you must submit a new disclosure that describes the change before continuing to engage in the activity.
Q 10. If I don’t file a Reportable Outside Activity Disclosure and engage in an outside activity, what are the consequences?
Disciplinary action for violating the policy will vary depending on the extent of the violation and may range from a warning to termination of employment.
Q 11. How is Consulting defined?
Consulting is an employee's use of their professional capabilities and knowledge for the benefit of a third party in return for immediate or prospective gain.
Q 12. Does this policy prohibit me from being a paid consultant for a corporation or for-profit company?
Consulting by tenured and tenure-track faculty is not prohibited as long as it does not present a Conflict of Commitment or exceed, on the average, one business day per week when combined with all other Reportable Outside Activities.
Before serving as a consultant, you must submit a Reportable Outside Activity Disclosure for approval.
Q 13. I am a tenured professor at Purdue, and I consult for several companies. Is there a time limitation on Consulting?
Consulting by tenure and tenure-track faculty members generally may not exceed, on the average, one business day per week during the term of appointment when combined with all other Reportable Outside Activities.
Q 14. I am co-founder of a company, but I do not have any income from this relationship yet. Is this a Reportable Outside Activity?
Yes. Participation as an owner or partner in a business enterprise must be reported.
Q 15. As a scientist, I am asked to participate in online surveys relative to my area of expertise. I am paid a small amount of money for this activity. Is this a Conflict of Commitment?
This would likely not be considered a Conflict of Commitment, but would be a Reportable Outside Activity because you are being compensated. Therefore, you must submit a Reportable Outside Activity Disclosure.
Q 16. May I take an honorarium for giving a lecture?
Yes; however, an Reportable Outside Activity disclosure must be submitted prior to engaging in the activity.
If you are an investigator on a sponsored project, the honoraria may need to be disclosed under the Individual Financial Conflicts of Interest policy.
Q 17. If I receive royalties or compensation for publishing works, is this a Reportable Outside Activity?
Yes. Depending on your responsibilities to the University, the royalties or compensation may also need to be disclosed in accordance with the Individual Financial Conflicts of Interest policy.
Q 18. I am a faculty member, and I am actively involved in a professional association related to my University duties. Is the work I perform for the association, including attendance at quarterly meetings, considered a Reportable Outside Activity?
No. Only service as an officer, director, trustee or public representative for such organizations needs to be reported.
Q 19. How does this policy work in relation to sabbatical?
If the activities a faculty member will engage in during sabbatical are Reportable Outside Activities, then a disclosure must be submitted and approved in advance. Faculty must also comply with the requirements of Executive Memorandum No. B-11 (Sabbatical Leave of Absence).
Q 20. I am an officer of a professional association, and my participation is necessary to maintain a license required for my job. Do I have to submit a Reportable Outside Activity Disclosure for this activity?
Yes. Participation in professional associations does not need to be reported, but service as an officer does.
Q 21. What if I don't agree with the conditions of a management plan?
You may appeal the conditions of a management plan in writing to the Vice President for Ethics and Compliance (VPEC) within 10 days of the determination. The VPEC will convene a committee to review the appeal, and the committee's decision on the matter is final.
Q 22. My Reportable Outside Activity Disclosure was denied. Can I appeal?
Yes. If you disagree with a determination regarding a request to engage in Reportable Outside Activities you may submit a written appeal to the Vice President for Ethics and Compliance (VPEC) within 10 days of the determination. The VPEC will convene a committee to review the appeal, and the committee's decision on the matter will be final.
Q 23. I am an Exempt Employee, but my consulting is strictly limited to nights and weekends. Do I need to report it?
Yes. All Reportable Outside Activity by Exempt Employees needs to be reported regardless of when it takes place. The only exception based on the time of the Activity is for volunteering outside of normal business hours.
Q 24. As an academic-year employee, do I need to report activity that occurs during the summer?
Yes, exempt academic-year employees including faculty members and graduate student employees must submit a disclosure and receive permission before engaging in a Reportable Outside Activity during the summer. Summer activities have the potential to present a Conflict of Commitment.
Q 25. I’m a part-time employee. Do I need to report my other job?
Yes, if you are an Exempt Employee at Purdue. Part-time employees are expected to devote their professional or occupational time and energy in accordance with their agreed upon commitments.
Q 26. I am a member of a family LLC. The LLC owns our family farm and a house that is rented. Do I need to report the LLC as a Reportable Outside Activity?
Yes. Participation in any business enterprise as an owner, partner, officer, supervisor, manager or in any capacity with management responsibilities is a Reportable Outside Activity that must be disclosed.
Q 27. I’m a faculty member, and I engage in consulting. I have an LLC for my consulting activities. Do I need to disclose the LLC in years when I don’t do any consulting?
Yes. Participation in any business enterprise as an owner, partner, officer, supervisor, manager or in any capacity with management responsibilities is a Reportable Outside Activity that must be disclosed. Because you still have an ownership interest in the LLC – even years where no consulting activity takes place -- the ownership interest must be disclosed.
Q 28. I’m a faculty member, and I do my consulting work through an LLC. Do I need to disclose each of the entities for whom the consulting work is performed?
Yes. The University needs to know the name of each entity for whom faculty and staff are doing work to appropriately address any Conflicts of Commitment and potential issues involving Individual Financial Conflicts of Interest (III.B.2).
Purdue addresses must not be used as your principal place of business in filings with state secretaries of state, tax returns, or any other purpose.
Q 29. Am I able to use University facilities, equipment, and resources for an approved ROA?
No. You cannot use University facilities, equipment, and resources for an approved ROA unless you have a specific contract approved. This prohibition includes your Purdue issued computer, Purdue IT resources including email, software, and your University office and/or work space, labs, and Purdue name and address.
Per IV.B.1 - University Policy Office - Purdue University: University Facilities may be used only by persons authorized by the CFO on the West Lafayette campus and by the Chancellors of the Regional Campuses (or their authorized representative) and only in the manner and for purposes authorized by the CFO or Chancellor. Regular, recurring use of a University Facility by a non-University entity and/or for private business use is permitted only by terms of a separate, specific contract approved by the CFO, Chancellor or authorized representative (see Third-Party Use of Facilities (S-2)).
Q 30. I'm a faculty member. Occasionally, I have the department administrative assistant perform clerical work during her Purdue work day for my consulting work through my LLC. Is this allowable?
No. This is a violation of Indiana criminal law for you as the supervisor as well as for the administrative assistant.