*** IMPORTANT UPDATE ABOUT ROA DISCLOSURES ***
As of Friday, August 8, 2025, at noon, it will not be possible to submit new ROA disclosures on the VPEC ROADD site. However, the ROADD site will remain available for recommendations and decisions to be entered as well as for historic information.New ROA pre-approval requests must be submitted using PERA’s Conflict of Interest/Conflict of Commitment Module. The PERA system includes training for conflicts of interest and conflicts of commitment. Once on the page, scroll down to see the available options.
Questions about PERA may be directed to the PERA Help Team at perahelp@purdue.edu.Questions about the ROA policy may be directed to compliance@purdue.edu.
Capitalized terms are defined in the policy. Please refer to the Definitions section.
Q 1. What is a Conflict of Commitment?
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
Reportable Outside Activity and Reportable Outside Activities do not include:
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?
Q 7. Where do I submit the Reportable Outside Activity disclosures?
When you land on the Purdue Excellence in Research Administration site (pera.research.purdue.edu), scroll down and click on the Conflict of Interest / Conflict of Commitment Module tile.
Training is available here: https://pera.research.purdue.edu/training/compliance/coi-coc/
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.
Q 31. The Conflicts of Commitment and Reportable Outside Activities (III.B.1) policy contains a provision regarding the preparation and publication of scholarly publications, i.e., books, articles, and other creative works. Although such activities are usually not ROAs, if a Foreign Adversary Entity (1) provides compensation for and/or (2) is involved as a publisher, co-author, co-editor, or some other role in the preparation and publication of scholarly communications, the activity is a Reportable Outside Activity that must be disclosed. What is a Foreign Adversary Entity?
For purposes of disclosures of ROAs, the term “Foreign Adversary Entity” means a business, governmental entity, or other entity (or any of their agents, trustees, or fiduciaries) organized under the laws of, headquartered in, or owned or controlled by citizens or the government of a Foreign Adversary Nation. Currently, China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela are Foreign Adversary Nations.
Q 32. How do I submit a Pre-Approval Disclosure of a Reportable Outside Activity for the exceptions described in Q31?
To disclose that a Foreign Adversary Entity (1) provides compensation for and/or (2) is involved as a publisher, co-author, or some other role in the preparation and publication of scholarly communications:
Q 33. I already submitted my ROA disclosures for FY2025-26 in the Reportable Outside Activities Disclosure Database [“ROADD”]. Am I required to re-submit the ROA disclosures in the PERA COI/COC module?
Faculty and staff are not required to re-submit ROA disclosures for the 2025-26 fiscal year that have already been submitted in ROADD. The FY2025-26 disclosures will not be imported into PERA. However, all faculty and exempt staff will need to complete the annual training on the Conflicts of Commitment and Reportable Outside Activities (III.B.1) policy and complete the certification regarding compliance with the policy in the PERA COI/COC module before September 30, 2025.
Q 34. I don’t have any ROAs to report. What do I need to do?
All faculty and exempt staff will need to complete the annual training on the Conflicts of Commitment and Reportable Outside Activities (III.B.1) policy and complete the certification regarding compliance with the policy in the PERA COI/COC module before September 30, 2025. If you do not have ROAs to disclose, you will need to certify that you do not have anything to disclose.