Conflicts of interest and outside activity reporting

All UW-La Crosse faculty and staff are required to report conflicts of interest.

Faculty, Academic Staff, and Limited Appointees report any outside activities following the outside activities reports guidelines. The guidelines and additional information are included in the first section below.

University Staff follow the reporting process outlined in the Code of Ethics. Resources and related information for University Staff are available in the second section below.

Managers and Supervisors are responsible for reviewing the information report by direct reports, identifying potential conflicts of interest and resolving them. Additional information is available below.

Any employee, manager, or supervisor who has questions or concerns may contact Human Resources for assistance.  

Faculty, Academic Staff, and Limited Appointees

Reporting requirements for Faculty, Academic Staff, and Limited Appointees expanding section

It is the policy of the University of Wisconsin System to require a report from all faculty, academic staff and limited appointees who engage in remunerative outside activities in their field of professional interest whose appointments are half-time or more for the period under contract to the UW System. If you have a joint appointment, you must file a report for each department/unit. Your report covers activities that occur during the full year, even if you were not under contract to the University for part of that time. You should discuss with your dean or director any activities that may present carryover questions of conflict with your responsibilities during your contract period. Additionally, while the form gathers information for the prior year, staff are required to report any changes in your circumstances as they occur as soon as possible.

Note: The President, Chancellor or his/her designee may provide exception to the deadline of completing this form in extenuating circumstances. Notwithstanding the exception, the employee must immediately submit this form upon his/her return to work.

What must be reported on the Outside Activities Report (OAR) form? expanding section

Faculty, Academic Staff, and Limited Appointees use the Outside Activities Report (OAR) form to report:

A remunerative relationship is any relationship that results in payments, transfer of goods or provision of services to the reporting staff member.

Net remuneration includes the value of all payments, goods and services received as compensation for an activity less expenses. Expenses deducted should not exceed those that could ordinarily be claimed from university administered funds.

An organization is any corporation, partnership, proprietorship, firm, enterprise, franchise, association, trust or the legal entity other than an individual or body politic (see Wis. Admin. Code § UWS 8.02(12).

Professionally related activities are activities related to the staff members’ field of academic interest or specialization.

Ordinary professional activities are those activities which extend an unclassified staff member’s normal institutional responsibilities of teaching, research and service to serving other public institutions, organizations, and professional societies.

Examples of such ordinary professional activities would be:

  1. Occasional lectures, colloquia, seminars, etc., given at colleges and universities and at meetings of professional societies.
  2. Preparation of monographs, chapters and editorial services for nonprofit educational organizations.
  3. Service on advisory committees and evaluation panels for government funding agencies, nonprofit foundations and educational organizations.
  4. Leadership positions in professional societies.

Please note: The annual economic interests reporting requirement administered by the Office of the Board of Regents is separate from and in addition to the outside activities reporting requirement. Pursuant to Wis. Admin. Code § UWS 8.06, the president, vice presidents, chancellors, and all contracting personnel must file a statement of economic interests with the Office of the Board of Regents annually, by April 30.

Those activities which are reportable under UWS 8.025 include:

  1. Professionally related outside activities occurring during the time you are under contract to the university for which you received net remuneration, not including ordinary professional activities.
  2. The names of organizations or businesses for which net remunerative outside activities were performed, the type of activity (consulting, teaching, research, writing, etc.) and the aggregate time spent (days) in that activity. Royalties from writing and patents need be reported only in the year that they first appear.
  3. You must name the organization or source and indicate the aggregate amount of time in days spent in outside activities with that organization. If you received $5,000.00 or more compensation per year from a single source, you must check the last column of section A. If you believe you should not publicly identify the name of the organization, you must receive approval from your dean to withhold the name (e.g., if revealing the name would be damaging to the organization’s legitimate competitive interests).
  4. Any remunerative relationships that you had with organizations which sponsor university research, teaching or training in which you are involved. If these relationships exist, you must report the name of the organization.
  5. Officerships, directorships, trusteeships that you or members of your immediate family hold in businesses or commercial organizations related to your professional field.
  6. Ownership interests in organizations related to your academic area of specialization, provided that your immediate family collectively owns more than 10% of the equity.

If an apparent conflict of interest is identified, the Institution shall contact UW System Human Resources for discussion and resolution. UW System Human Resources, the Office of General Counsel and the Institution will review and resolve the conflict and attach related documentation to the form.

Those activities which need not be reported include:

  1. Activities for which remuneration comes from university administered funds (e.g., teaching and innovation awards, etc).
  2. Remunerative ordinary professional activities (see definitions above).
  3. Instruction at another nonprofit educational institution or research supported by a government agency if the instruction or research is performed during periods when the staff member is not on the university payroll, or, in the case of part-time appointment, if the work is performed during time not contracted to the university.
Timeline and Escalation Process expanding section

The annual due date for the Outside Activities Report (OAR) form for Faculty, Academic Staff, and Limited Appointees (with at least 50% appointment) is April 30. 

March Human Resources will provide a reminder to all faculty and staff of (1) the obligation to inform all faculty and staff of Regent Policy Document 13-4 on institutional and employee relationships with educational loan lenders, (2) the UW System policies and obligations for faculty, academic staff, and limited appointees to report on outside activities, and (3) the requirement to advise University Staff of their obligation to avoid conflicts of interest.
March Faculty, Academic Staff, and Limited Appointees who are required to complete an Outside Activity Report will be notified via email with specific instructions on how to submit these forms for all activities occurring in the previous calendar year.
April 1
April 15
April 28
Email reminder notices will be sent to employees who have not completed the OAR form requirement. Employees who do not receive email reminders may assume that HR has received their completed form.
April 30 Forms must be returned to Human Resources no later than April 30.
May 1 Email receipts for all completed forms will be sent to employees. 
May 1 An email will be sent to employees for whom HR does not have a completed form. Employees will have the opportunity to address potentially misplaced or processed, but not yet received forms.  These employees may be eligible to resubmit the forms. 

Important: while the OAR form gathers information about the prior year, staff are required to report any changes in circumstance as they occur as promptly as possible. 

Outside Activities Reporting Process expanding section

Procedures for completion of Outside Activities Reporting (OAR) form:

  • Print the Outside Activities Form and complete a form for each position you have at UWL.
  • Even if you have no Outside Activity to report, you must complete the form for each position you have at UWL.
  • Route the completed form to your dean/division officer for their signature.
  • Your dean/division officer will complete the process and forward to Human Resources
What happens if I do not comply with reporting outside activities? expanding section

UW-La Crosse employees who do not comply with reporting outside activities will be considered "not in good standing" and be documented with a performance rating of "unsatisfactory."  Employees with unsatisfactory ratings may not be eligible for base adjustments, lump sums and pay plan adjustments. Further actions may also result in related non-compliance with UW System policies. 

What is an Institutional Ethics Committee? expanding section

Wis. Admin. Code § UWS 8.035 requires that each institution shall have an institutional ethics committee, “whose function shall be to provide to any member of the unclassified staff consultation and advice on the application” of Chapter UWS 8 Unclassified Staff Code of Ethics. The institutional ethics committee can either be established or designated as part of an existing committee.

Additional Resources expanding section

Additional resources regarding conflicts of interest are included below:

University Staff

Reporting requirements for University Staff expanding section

The University Staff Code of Ethics is set forth in the section III of Regent Policy Document 20-22: Code of Ethics (RPD 20-22). University Staff are advised to review this policy in its entirety and to abide by the actions identified to avoid possible conflicts between personal interests and public responsibilities as an employee of UW-La Crosse and avoid sanctions. 

All staff should review annually Regent Policy Document 13-4 on Institutional and Employee Relationships with Educational Loan Lenders.

What is the timeline to report potential conflicts of interest? expanding section

When it appears that a material conflict of interest may arise between the personal interests of a University Staff member and his or her public responsibilities, the University Staff member shall notify his or her supervisor or other appropriate administrator by submitting a written statement describing the nature of the possible conflict. Next steps are available in Regent Policy Document 20-22: Code of Ethics.

What happens if I don’t comply with reporting potential conflicts of interest? expanding section

UW-La Crosse employees who do not comply with reporting outside activities will be considered "not in good standing" and be documented with a performance rating of "unsatisfactory."  Employees with unsatisfactory ratings may not be eligible for base adjustments, lump sums and pay plan adjustments. Further actions may also result in related non-compliance with UW System policies. 

What is an Institutional Ethics Committee? expanding section

Wis. Admin. Code § UWS 8.035 requires that each institution shall have an institutional ethics committee, “whose function shall be to provide to any member of the unclassified staff consultation and advice on the application” of Chapter UWS 8 Unclassified Staff Code of Ethics. The institutional ethics committee can either be established or designated as part of an existing committee.

Additional Resources expanding section

Additional resources regarding conflicts of interest are included below:

Managers and Supervisors

Review Process expanding section

When a manager/supervisor receives an OAR form with reported outside activities, they should take the following steps:

  • Review the information on the OAR form
  • Determine if there is a potential conflict of interest. Review Ethics information available from the UW System Office of General Counsel. If you determine there is a potential conflict of interest:
    • Meet with the employee to ask questions relation to resolving the potential conflict(s).
    • Contact the UW-La Crosse Chief Officer of Human Resources for assistance and involvement as needed.
  • Sign off on the form and return it to Human Resources by April 30. 
Additional Resources expanding section

Additional resources regarding conflicts of interest are included below: