Conflicts of Commitment and Reportable Outside Activities (III.B.1)

Volume III: Ethics
Chapter B: Conflicts
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Office of Vice President for Ethics and Compliance
Date Issued: July 1, 2011
Date Last Revised: June 30, 2025

Table of Contents

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Statement of Policy

The University recognizes that Reportable Outside Activities can in many circumstances offer important opportunities for employees to expand their professional horizons, provide valuable public service, and transfer their skills and knowledge for the benefit of the community at large. Reportable Outside Activities, however, should be structured to avoid a Conflict of Commitment. The specific responsibilities and activities that constitute an appropriate and primary commitment to the University will vary among units and will depend on the nature of each employee's responsibilities, but must be based on and consistent with this policy.

A full-time Exempt Employee’s primary professional or occupational commitment is to the University. Part-time Exempt Employees are expected to devote their professional or occupational time and energy in accordance with their agreed upon commitments. No Employee may engage in a Reportable Outside Activity that gives rise to a Conflict of Commitment.

To make sure that an appropriate balance is achieved, no Exempt Employee may engage in a Reportable Outside Activity until 1) the employee has submitted a Reportable Outside Activity Disclosure and 2) the Unit Head or OA Officer has given written approval for the employee's participation in the Reportable Outside Activity Disclosure. Each Unit Head has a continuing obligation to monitor the Reportable Outside Activities of Exempt Employees they supervise and to withdraw in writing any previously granted permission if the Unit Head determines that the Reportable Outside Activity has resulted in a Conflict of Commitment for an Employee. Approval to engage in a Reportable Outside Activity does not alter or diminish the Exempt Employee’s duties or responsibilities to the University.

Consistent with its missions of discovery, delivery and engagement, the University encourages its tenured and tenure-track faculty to practice their professions. Such practice is often enhanced by engaging in Consulting. When combined with all other Reportable Outside Activities, Consulting by tenure or tenure-track faculty members generally may not exceed, on the average, one business day per week during the term of their appointment.  

No tenured, tenure-track or full-time member of the faculty may hold tenure at any institution other than Purdue University, except in extraordinary circumstances and with the specific written permission of the Provost or the Vice Chancellor for Academic Affairs, as the case may be.

Situations involving Reportable Outside Activities also may involve issues addressed in the University's policies on Intellectual Property (I.A.1), the Research Security Program (I.A.6), Travel for University Business (II.A.3), Effort Reporting (II.C.1), Individual Financial Conflicts of Interest (III.B.2), Gifts, Gratuities and Recognition (III.B.5),  and Use of Facilities (IV.B.1). Employees must comply with these and all other applicable policies and regulations, including but not limited to those regarding leaves and sabbaticals.

Exempt Employees may be subject to appropriate discipline if they:

• fail to submit a Reportable Outside Activity Disclosure for any Reportable Outside Activity,
• submit an incomplete, misleading or inaccurate Reportable Outside Activity Disclosure,
• engage in any Reportable Outside Activity without the written permission of their Unit Head or the OA Officer, or after such permission has been withdrawn,
• fail to submit an updated Reportable Outside Activity Disclosure if the scope or nature of a Reportable Outside Activity changes, or
• otherwise violate any of the provisions in this policy.

Reason for This Policy

This policy provides a framework for evaluating employee requests to engage in Reportable Outside Activities based on the fundamental principle that all full-time Exempt Employees’ primary professional or occupational commitment is to Purdue University. The University believes it is necessary to maintain sufficient flexibility for evaluating such requests using criteria appropriate to the individual units in which employees work. Such an approach provides Exempt Employees with meaningful guidance for the continued development and future structuring of productive external relationships.

This policy provides assurance to employees, the university community, federal and state agencies, and the public that potential Conflicts of Commitment are examined and conducted in a manner consistent with institutional and public values. It is intended to maintain the professional autonomy of Exempt Employees as appropriate to their respective disciplines and professions and to protect Exempt Employees from unwarranted suspicion that their Reportable Outside Activities divert them from fulfilling their responsibilities to the University or that those Reportable Outside Activities may improperly influence university decisions or operations.

This policy also provides a mechanism for evaluation of risk from participation in activities or affiliations 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 the University’s research enterprise.

Finally, this policy promotes compliance with Indiana Code 35-44.1-1-3, which prohibits ghost employment with governmental entities.

Individuals and Entities Affected

All units and Employees of Purdue University are governed by this policy.

Exclusions

Due to the nature of their appointments and responsibilities, outside employment and other Reportable Outside Activities of Nonexempt Employees that take place during off hours or during leave time will, in most circumstances, not divert their attention from university duties and will not represent a Conflict of Commitment. Therefore, Nonexempt Employees are required to disclose only those Reportable Outside Activities noted in the Responsibilities section of this policy.

Responsibilities

• Evaluate appeals from Employees regarding management of real or potential Conflicts of Commitment arising from proposed Reportable Outside Activities.

Exempt Employees

• Before engaging in any Reportable Outside Activity, submit a Reportable Outside Activity Disclosure and obtain the approvals required by this policy and its supporting procedures.
• For previously approved Reportable Outside Activities, submit a Reportable Outside Activity Disclosure annually as long as participation in the Reportable Outside Activity continues.
• Submit an amended Reportable Outside Activity Disclosure if the scope or nature of a Reportable Outside Activity changes.
• Following approval of a Reportable Outside Activity, continue to devote their time, energy and loyalty to the missions, goals and programs of the University that are relevant to their employment duties.
• Consult with the OA Officer and/or the VPEC on questions of what constitutes a Reportable Outside Activity or any other questions regarding the proper interpretation of this policy.
• Complete periodic training on this policy as outlined in the Operating Procedures.
• On an annual basis, complete the certification process regarding compliance with this policy as outlined in the Operating Procedures.

Nonexempt Employees

• Prior to the start of the activity, submit a Reportable Outside Activity Disclosure and obtain the required approvals for any Reportable Outside Activity that may interfere with the employee’s normal university duties (e.g., occurs during normal work hours or on-call hours) or when the activity includes involvement in a recruitment program affiliated with or organized by a foreign nation.

OA Officer

• Administer this policy.
• Provide guidance and training to Unit Heads regarding this policy’s operating procedures, as appropriate.
• Upon request, assist employees and Unit Heads concerning the proper interpretation and implementation of this policy.
• Review and make determinations in a timely manner on Reportable Outside Activity Disclosures routed to the OA Officer for a determination.
• Work with Unit Heads to formulate managements plans for real or potential Conflicts of Commitment arising from proposed Reportable Outside Activities.
• Audit approved Reportable Outside Activities for compliance with this policy and its supporting procedures. Withdraw approval for a Reportable Outside Activity deemed to meet the definition of a Conflict of Commitment.

 Research Security and Export Control

• Review and make determinations in a timely manner on disclosures of participation in or affiliation with Foreign Talent Recruitment Programs and other foreign programs to determine whether the program is malign or otherwise prohibited by federal or state law or regulation or other governmental order.
• Review Reportable Outside Activity Disclosures involving non-U.S. entities and determine whether or not to recommend approval of the activity based on factual analysis of the relevant risks associated with the activity.

Unit Heads

• Upon request, help employees under their supervision understand and comply with this policy.
• Review and make determinations in a timely manner on Reportable Outside Activity Disclosures routed to them.  
• Promptly forward disclosures to the OA Officer when the Unit Head requires the advice of the OA Officer and/or wants the OA Officer to make the determination.

 VPEC

• Serve as the OA Officer or designate another employee to do so.
• Appoint and chair an ad hoc appeals committee upon receipt of an appeal from an employee.
• Provide copies of the ad hoc appeals committee’s decision on an employee appeal regarding a Reportable Outside Activity to the pertinent Unit Head and the requesting employee.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

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 activities 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 activities 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.

Consulting
An Exempt 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.

Exempt Employee
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.

Foreign Talent Recruitment Program
Any program, position or activity that includes compensation from:

1. a foreign country at any level (national, provincial, or local) or their designee, or
2. an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country.

The compensation may or may not be stated in the arrangement, contract or document at issue and includes:

1. direct payment (cash),
2. in-kind compensation, including research funding, promised future compensation, complimentary foreign travel, things of non de minimus value, honorific titles, career advancement opportunities, or
3. other types of remuneration or consideration.

Nonexempt Employees
Employees of Purdue, wherever located and whether full-time or part-time, including but not limited to those in clerical, service, trade or operational support roles who typically are paid an hourly wage, including those on leave of absence with or without pay.

OA Officer
The Outside Activities Officer, which will be the VPEC or designee.

Reportable Outside Activity and Reportable Outside Activities
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
• Service without compensation 1) on U.S. federal or state government agencies and boards, 2) on U.S. federal or state granting agency peer-group review panels, 3) on advisory groups for other U.S. universities or 4) in similar capacities primarily for the purpose of providing a public or University service within the United States

Reportable Outside Activity Disclosure
Purdue University’s online Reportable Outside Activity Disclosure system. The information contained in the disclosure and related documentation is considered part of the Employee’s personnel file.

Unit Head
The applicable dean, vice chancellor, chancellor, associate or assistant vice president, vice president, CFO, associate or assistant provost, Provost or President who has executive management responsibilities for supervising the Employee. The chairperson of the Board of Trustees serves as the Unit Head of the President and any other Employees who report directly to the Board of Trustees. The President serves as the Unit Head for all Employees reporting directly to the President.

Related Documents, Forms and Tools

• Frequently Asked Questions
• Operating Procedures for Submitting and Reviewing Reportable Outside Activity Forms
• Guidelines for Completion of the Reportable Outside Activity Form

 Related Policies:

• Effort Reporting (II.C.1)
• Export Controls and OFAC Regulations (I.A.2)
• Individual Financial Conflicts of Interest (III.B.2)
• Research Security Program (I.A.6)
• Use of Facilities (IV.B.1)

Indiana Code 35-44.1-1

National Science and Technology Council’s Guidance for Implementing National Security Presidential Memorandum 33 (NSPM-33)

Website Address for This Policy

www.purdue.edu/policies/ethics/iiib1.html

History and Updates

June 30, 2025: Policy updated to clarify differing responsibilities of Exempt Employees and Nonexempt Employees. Added language pertaining to risk from participation in activities or affiliations with any non-U.S. entity. Updated definitions of Conflict of Commitment, Foreign Talent Recruitment Program and Reportable Outside Activities. 

July 1, 2024: Definition of Foreign Talent Recruitment Program updated to match Research Security Program policy (I.A.6).

January 8, 2024: Included definition of Foreign Talent Recruitment Program and updated definitions of Reportable Outside Activity and Conflict of Commitment. Added responsibilities for the Research Security Office.

July 15, 2021: Update to definition of Reportable Outside Activity to include exclusion for Purdue Applied Research Institute.

January 1, 2019: Replaced the standing Conflicts Committee with an ad hoc appeals committee and replaced annual reporting by the Unit Head with auditing by the OA Officer. Other administrative and clarifying updates throughout.

August 31, 2012: References to Indiana Code updated to reflect new numbering.

May 16, 2012: Related Documents section updated.

November 18, 2011: Policy number changed to III.B.1 (formerly X.2.4) and website address updated. Related Documents section also updated.

July 1, 2011: This policy supersedes Executive Memorandum No. C-39, University Policy on Conflicts of Interest and Commitment, dated October 25, 1995.

This policy accompanies the policy on Individual Financial Conflicts of Interest (III.B.2).

Appendix

There are no appendices to this policy.