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Handbook of Operating Procedures
Chapter 4 - Personnel - General
Publication Date: February 7, 2020
Policy Reviewed Date: October 19, 2022
Policy Owner: President

4.32 Institutional Conflicts of Interest


It is the policy of The University of Texas at San Antonio (UTSA) that Institutional Conflicts of Interest (ICOI) cannot be allowed to compromise, or to appear to compromise, the academic integrity and freedom of faculty in teaching, research, or service; the administration's obligation to assure that institutional decisions serve UTSA's primary missions; or, the institution's obligation to use its economic and physical resources in the best interests of scholarship and its faculty, staff, and students. While UTSA recognizes that University-industry relationships are essential for advancing scientific frontiers and enabling the commercial development of academic discoveries to the benefit of the public, UTSA must balance the risk to its primary missions as the institution engages in relationships that lead to financial or reputational benefit for the institution or its responsible officials.


This policy assures the identification, evaluation, and management of situations that create a risk of ICOI, or the appearance thereof. This policy applies in addition to general UTSA policies, such as policies on standards of conduct, as well as other policies governing conflict of interest.


This policy applies to all University employees and all University business.



List any related UTSA or UT System policies, or Board of Regents rules, as well as any related local, state, or federal legislation or administrative regulations, and provide a link to each.

Include any other related documents that led the Sponsoring Office to propose the policy, or that provide helpful information (contracts, guidelines, professional standards, surveys, etc.)

UTSA or UT System Policies or the
Board of Regents Rules & Regulations

Other Policies & Standards

UTS 189 Institutional Conflicts of Interest

Texas Government Code Chapter 572 - Personal Financial Disclosure, Standards of Conduct, and Conflict of Interest


If you have any questions about HOP 4.32 Institutional Conflicts of Interest, contact the Office of the President:

The Office of the President
(210) 458-4101


Executive Officer- the president and all individuals who report directly to the president (other than administrative support positions).

Institutional Conflict of Interest Committee – individuals who review disclosures to determine if they constitute an Institutional Conflict of Interest and recommend how they may be managed.

Institutional Conflicts of Interest (ICOI) – may exist when UTSA’s interests or relationships or an Institutional Official, acting within his or her official capacity on behalf of UTSA, compromises, or appears to compromise, decisions involving research and discovery; teaching and learning; community engagement and public service; and any business activities, transactions and investments therein.

Institutional Official – Executive Officers and any other employee who exercises broad and significant discretion over key UTSA functions.

Institutional Interests – may be held by UTSA or Institutional Officials and may include, but are not limited to royalty payments; substantial equity and ownership interests; gifts; licensing activities; contracts for goods and services; governance or fiduciary roles; purchasing; research activities; commercialization activities; educational and training activities; other financial interests; and other administrative decisions.


  1. Institutional Conflict of Interest Committee

    1. The Committee will evaluate potential ICOI, or the appearance thereof, and determine whether UTSA has an interest in managing the situation and, if so, recommend to the President the terms and conditions necessary to minimize the risk of undue influence on UTSA decisions, functions, and actions, up to and including the prohibition or elimination of the interest or relationship that creates the ICOI.
    2. No member of the Committee may participate in an initial or continuing evaluation of an ICOI in which that member has an interest or relationship that compromises, or appears to compromise, the Committee's evaluation, except to provide information requested by the Committee.
    3. The Committee will develop guidelines and procedures for specific categories of ICOIs that present minimal risk to the integrity of the institution and that can be handled administratively by Institutional Officials with monitoring plans and documentation.
    4. The Committee will develop and provide awareness training and procedures for self-assessment and monitoring to employees and offices whose responsibilities may be affected by ICOI.
    5. In the event that an ICOI relates to an Institutional Interest or relationship of the President, the Committee will report its recommendations directly to UT System Administration.

    Institutional Official Responsibilities

    1. Institutional Officials shall disclose Institutional Interests or relationships that create the possibility for significant financial or reputational risk for the institution to the Committee for review before receiving or entering into the interest or relationship. Institutional Officials shall disclose Institutional Interests that create the possibility for minimal financial or reputational risk for UTSA to the Committee based on guidelines set by the Committee.
    2. Institutional Officials will comply with the terms and conditions of all ICOI Management Plans.
    3. This policy does not replace the responsibility of Institutional Officials to disclose individual interests and relationships, nor the responsibility of University officials to identify and manage individual conflicts of interest, under the standards and procedures of University policies governing individual conflicts of interest (HOP 1.33 and HOP 10.04)

    University and Community

    1. All UTSA employees have the duty to promptly report any perceived, potential, or actual ICOI of which he or she becomes aware to his/her unit head (e.g., department head, center director, and vice president) or directly to the Committee Chair.
    2. UTSA will implement a system to allow anonymous disclosure of any situation suspected to involve an ICOI to the Committee for review.
    3. UTSA will maintain a searchable database of identified ICOIs to be referenced and used when considering any new contract, agreement, or other arrangement that could create an ICOI. This database will be made available to Committee members, the Office of Academic Affairs, the Office of Research, Economic Development and Knowledge Enterprise, the Office of Business Affairs, the Office of Development and Alumni Relations, Institutional Compliance and Risk Services, and any Institutional Officials responsible for institutional activities related to an ICOI.
    4. University students, affiliates, and community members are strongly encouraged to disclose any situation suspected to involve an ICOI to the Committee for review.


Institutional Conflict of Interest Committee
UTSA shall create and maintain an Institutional Conflict of Interest Committee (“the Committee”). Four Committee members will be appointed by the President and five will be ex-officio members. One voting member will not be affiliated with UTSA. Three Committee members must be tenured faculty members at the Associate Professor or Professor rank, chosen from a list of at least six eligible faculty members created by the Faculty Senate. The President will appoint one of the faculty to serve as Committee chair.

Ex-officio, voting members will be the Faculty Senate Chair; the Senior Vice President for Business Affairs; the Vice President for Research, Economic Development, and Knowledge Enterprise; the Vice President for Development and Alumni Relations; and the Research Integrity Officer. The Chief Legal Officer will attend meetings as a non-voting member and serves as legal advisor to the Committee.

Appointed members who are not ex-officio will serve three year terms and may be reappointed by the President for additional terms. Any vacancies of appointed members will be filled by Presidential appointment to serve the remainder of the unexpired term.

Quorum is defined as one more than half of the voting members and must be maintained for all Committee votes. Because of the sensitivity of the topics addressed, meetings generally will be closed to visitors. However, invitations to attend a portion of the Committee meeting may be extended to individuals with special expertise related to agenda topics. Additionally and at its discretion, the Committee may appoint non-voting ex-officio members for renewable one-year terms.

The Office of the President will provide administrative support for Committee operations.

Records regarding the disclosure of ICOIs, evaluations by the Committee, implementation of Management Plans, and other records of UTSA actions, must be retained according to the UTSA records retention schedule.

Institutional Compliance and Risk Services will provide for a centralized repository for disclosure statements, Management Plans, related records, and reports.

The Committee Chair, or another person designated by the President, will provide the Chancellor of The University of Texas System with copies of all guidelines, procedures, and forms used by the University relating to Institutional Conflicts of Interest and must ensure that the Chancellor receives copies of any revised guidelines, procedures, and forms simultaneously with the implementation of the revision.

UTSA will provide for regular reviews of disclosure statements and Management Plans to determine individual and University compliance with this policy.

Noncompliance with this policy may subject an employee to discipline in accordance with applicable procedures up to and including termination of employment.




The UTSA Disclosure of Outside Activity and Interests form is located here: [FORTHCOMING; currently at ]