Conflict of Interest (COI)

  • A conflict of interest can occur when a member of the university community is in a position to gain, or appear to gain, financial advantage or personal benefit (broadly construed) arising from their University position, either through outside professional activities or through their research, administrative, or educational actions or decisions at the university. Because university employees are also State employees, provisions of the Maryland Public Ethics Law and university policies in regard to outside activities apply.

  • Maryland Public Ethics law applies to all State of Maryland employees.

  • The Maryland Public Ethics Commission provides information, guidance and examples of conflicts.

  • In general, COI situations should be avoided.  Procurement must confirm there are no conflicts of interests regarding the contractor’s ability to provide goods or services to the university before entering into a procurement.  This requires a complete review of company ownership information, and an understanding of the relationships involved in the COI.

  • At UMD, apparent COI situations are escalated and carefully vetted by the Director of Strategic Sourcing or AVP for P&BS to: 
  1. Determine if a COI exists (may include consultation with the Office of General Counsel)
  2. Consult with the Conflict of Interest Officer to determine if the conflict is related to research.  If the conflict of interest is associated with research efforts it is referred to the University of Maryland Conflict of Interest Committee for review and disposition.  In some cases, conflicts of interest approved by the Conflict of Interest Committee may be allowed and the procurement will proceed.
  3. Determine the appropriate course of action for non-research related conflicts of interest.

  • If a conflict of interest is determined to exist, the Director or AVP will consult with the Office of General Counsel, Conflict of Interest Officer, and others on campus to determine an appropriate path forward.

  • Conflict of Interest situations may be referred to authorities at the State of Maryland for a written opinion before the procurement can be resolved.

  • Disclosure of potential COI is critical to ensure Maryland Public Ethics Laws and university policies are not violated.