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 Cooperative Extension


UW-EXTENSION COOPERATIVE EXTENSION
CONFLICT OF INTEREST POLICY

SCOPE

This policy covers non-integrated cooperative extension employees, regardless of percentage of appointment.

GENERAL POLICY

The nature of cooperative extension work requires considerable direct public contact. The public generally views Extension employees as educators who represent the outreach component of their land-grant institution, The University of Wisconsin. Thus, Cooperative Extension must guard against becoming involved in situations in which its public trust is questioned. Certain employment for personal gain, outside one's extension work, could lead to a material conflict of interest or a violation of public trust and/or use of public funds. Federal legislation requires guidelines be in place to address real or perceived conflicts of interest.

As stated in UWS 8.025 (1), Wisconsin Admin. Code, "Members of the unclassified staff are free to engage in outside activities, whether or not such activities are remunerative or related to staff members' fields of academic interest or specialization. However, no member of the unclassified staff may engage in an outside activity if it conflicts with his or her public responsibilities to the University of wisconsin system or the institution at which the unclassified staff member is employed."

In general, if it may appear that a Cooperative Extension employee is using his or her position to gain or promote personal outside activities for pay, a conflict of interest situation may exist and should be discussed with the appropriate administrator before initiating the activity. For state specialists, the administrator is the program leader. For area and county faculty and staff, the administrator is the district director.

OUTSIDE CONSULTING AND OUTSIDE TEACHING FOR PERSONAL GAIN

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Outside consulting and outside teaching for personal gain are activities that could be perceived as material conflicts of interest. If an employee is considering undertaking either of these activities for personal gain, the employee must notify his or her administrator before initiating the activity.

  1. Outside Consulting or Owning a Business
    Consulting is an external professional activity for personal gain. Any consulting that is done by a Cooperative Extension employee must be both outside the employee's job responsibilities and outside the Cooperative Extension employee's assigned geographic area. For state specialists, geographic area means the state of Wisconsin. For area and county faculty and staff, geographic area means the extension district of which your office is a part. Also, for all activities:

    1. Consulting and owning a business are done as a private citizen. Therefore, they must be done on the employee's own time and should not detract from his or her duties with Cooperative Extension.

    2. The names of Cooperative Extension or University of Wisconsin Extension should not be associated with the consulting or business work and Extension owned supplies and resources should not be used.

    3. Ownership or operation of a farm or other outside business is permitted but must not, as a result of the employee's extension job, compete unfairly with similar private businesses.

  2. Outside Teaching
    For the purpose of this policy "outside teaching" is paid employment with another educational institution.

All staff are expected to devote their vocational efforts and abilities to Extension purposes. A degree of flexibility is required that normally precludes outside teaching. It is also recognized that occasional outside teaching may enhance the employee and Cooperative Extension's professional reputation and increase interinstitutional cooperation.

 

In the case of part-time staff or staff working specified hours, there is a much clearer distinction between their actions as employees and as a private individuals. Thus, more latitude can be exercised regarding outside employment.

  1. Outside teaching at a UW System campus or any other state agency institution for personal gain.

    Teaching is permitted, but must be an unusual, short-term (week, month, semester) non-recurring assignment. Also, according to sec. 16.417(2), Wis Stats, no individual may receive more than $12,000 from the agency or campus for compensation for the individual's services during the same year.

  2. Outside teaching at a private college or university for personal gain.

    Teaching is permitted, but must be performed on the employee's own time.

(UWEX 8.05, ADMINISTRATIVE CODE) ACTION TO AVOID POSSIBLE CONFLICT

  1. When it appears that a material conflict may arise between the personal interests of a staff member and his or her public responsibilities to the University, the staff member shall notify his or her dean, director, or other appropriate administrator by submitting a written statement describing the nature of the possible conflict.

  2. Within 15 days after receipt of the statement, the dean, director or other appropriate administrator shall advise the staff member in writing that:

    1. There is no conflict prohibited by this chapter and the staff member may proceed; or

    2. There may be a conflict and further consultation is necessary prior to reaching a determination; or

    3. There is a conflict which must be resolved in one of the following ways:

      1. The staff member shall not proceed with his or her University duties which result in the conflict, so long as the conflict remains; or

      2. The staff member shall not proceed with his or her personal interests which result in the conflict, so long as the conflict remains.

      3. If the staff member is advised that sub. (2)(c) 1 or 2 applies to his or her case, the staff member, within 15 days after notice of the decision of the dean, director, or other appropriate administrator, may appeal the decision under ch. UWS 6 or 13.

      4. Record of the request and administrative response shall be placed on file with the staff member's annual statement of outside interests. Upon approval of the dean, director, or other appropriate administrator, the nature of a business or organization may be sufficient for this record if disclosure of the name of the business or organization is deemed to be inappropriate.

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(UWEX 8.06 ADMINISTRATIVE CODE) REPORTING OUTSIDE ACTIVITIES

  1. The following outside activities must be reported to the individual's dean, director, or other appropriate administrator:

    1. Associations with organizations related to the unclassified staff member's field of academic interest or specialization (see UWEX 8.02(3) for definition of "associated").

    2. Private remunerative relationships between unclassified staff members and non-governmental sponsors of University research in which the staff member is a principal investigator.

    3. Remunerative outside activities in an unclassified staff member's field of academic interest or specialization, including but not limited to consulting, and whether the staff member earns for such activities $5,000 or more in a year from a single source.

  2. Each unclassified staff member engaging in outside activities shall annually, on or before April 30, file a report of outside activities with his or her dean, director, or other appropriate administrator. These reports shall, unless otherwise privileged by law, be a matter of public record. One copy of this report shall be kept on file in the divisional office. Another copy of this report shall be placed in the unclassified staff member's official personnel file. Upon approval of the dean, director, or other appropriate administrator, a description of the nature of a business or organization may be sufficient for this record if disclosure of the name of the business or organization is deemed to be inappropriate.

  3. If, during the year, significant changes in a staff member's reportable outside activities occur, the staff member shall immediately inform, in writing, his or her dean, director, or other appropriate administrator. (See UWEX 8.05) - 2/2/98.

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