University of Illinois System Policies on Conflict of Interest

The University of Illinois System adopted several policies to identify and manage conflicts of interest. Applicability is based on your University appointment and responsibilities, you may be subject to more than one policy. Please review the chart below.

PolicyWho does this policy apply to?
Policy on Outside Activities and 
Conflicts of Commitment and Interest
2024 COCI policy web page
2024 COCI policy PDF
All “Covered Individuals” as defined by the Policy: includes academic professionals, academic hourlies, hourly faculty, postdoctoral associates, and the faculty ranks for professor, associate professor, assistant professor (and all of the foregoing whose appointments contain such terms as “specialized”, "research", "adjunct", “visiting", “teaching”, "clinical", or “emeritus”), instructors, and lecturers. This definition includes retired individuals with active appointments, as well as individuals with 0% unpaid appointments* consistent with those named above who have University Responsibilities involving University research or who have access to University laboratories or equipment for the purpose of research.
*Individuals with 0% unpaid appointments that have University Responsibilities involving only didactic teaching or non-research appointments may be exempted on a year-by-year basis by the Unit Executive Officer (“UEO”) from this Policy’s disclosure requirements.
Financial Conflicts of Interest in Research
2024 FCOIR policy web page
2024 FCOIR policy PDF
Investigators - anyone, regardless of title or position, who is responsible for the design, conduct or reporting - on sponsored research awards. This includes principal investigators, co-principal investigators, senior/key personnel and could include graduate students, civil service staff, and consultants (not employed by the University of Illinois).
Organizational Conflicts of Interest
2024 OCOI policy web page
2024 OCOI policy PDF
Key Organizational Leaders - administrators at the dean level and above

As a standard of conduct, the University of Illinois complies with organizational conflict of interest as defined in 2 CFR 200.318(c)(2). Organizational Conflicts of Interest (OCI) means that because of relationships with a parent company, affiliate, or subsidiary organization, the recipient or subrecipient is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization. The university implements disclosure and reviews consistent with sponsor regulations and award terms. If the effects of a potential or actual OCI cannot be avoided, eliminated, or mitigated, the procurement or other transaction anticipated by University will not be made using federal sponsor or cost share funds