Conflict of Interest and Commitment Policy

Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff, and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including the USC Health System and its subsidiaries (“USC Employees”). This policy continues to apply to individuals who are on sabbatical or other leaves, or who are visiting other institutions.

1. Policy

Issued: 08/14/2015
Last Revised: 04/29/2022
Last Reviewed: 04/29/2022

2. Policy Purpose

At the University of Southern California (“USC”), our values provide the foundation for the actions we take and guide our decisions as we work to achieve our fundamental commitment to our mission of excellence in teaching, research, caring for patients, athletics, and service to community.

We act with integrity when carrying out our responsibilities. Each of us is accountable for ensuring that no Conflict of Interest or Conflict of Commitment arises that may interfere with our ability to perform work for the benefit of USC and its students, patients, and partners. Our guiding principle is never to permit actual or perceived Conflicts of Interest to interfere with our professional commitment to USC.

In light of these accountabilities, all USC Employees must disclose actual or potential conflicts to their supervisor, department chair, or Dean and report them to the Office of Culture, Ethics and Compliance as set forth below. No employee should engage in activities that give rise to an actual or potential Conflict of Interest until the conflict has been disclosed and addressed. Early disclosure and resolution enable all of us to focus on the mission of USC. Many potential conflicts can be resolved through a plan to mitigate the actual conflict or potential conflict.

Employees should report actual or potential Conflicts of Interest that involve an employee’s supervisor, department chair, Dean, or management to the Office of Culture, Ethics and Compliance.

While no policy can anticipate the full range of activities that may give rise to Conflicts of Interest, this policy is intended to help identify actual or potential conflicts and to describe the steps that will be taken to review and address conflict scenarios.

3. Scope and Application

This policy represents USC’s commitment to address professional, financial, personal, and commitment Conflicts of Interest. Certain activities and roles may trigger additional or distinct regulatory or legal obligations. The following USC policies are intended to address these types of conflicts:

  • USC’s Conflict of Interest in Research policy contains additional Conflict of Interest requirements specific to research activity, and applies to USC Employees and students involved in proposing, conducting, and/or reporting research.
  • USC’s Relationships with Industry policy contains additional Conflict of Interest requirements specific to the provision of healthcare and applies to USC Employees and students who are healthcare professionals.

All actual or potential Conflicts of Interest must be brought to a USC Employee’s supervisor, department chair, or Dean’s attention and reported through “diSClose,” USC’s online system for conflict disclosure. Conflict of Interest notifications and disclosures should be made as soon as feasible after discovery of a potential or actual Conflict of Interest. Matters related to giving or accepting gifts or hospitality are addressed in the following USC policies:

4. Definitions

TermDefinition
Close RelationFamily members (spouses, domestic partners, siblings, parents and children, grandparents, grandchildren, and any individual related by blood or affinity whose close association with the employee is the equivalent of a family relationship) and other persons with a Personal Relationship with a USC Employee. 
Conflict of CommitmentArises when a USC Employee undertakes a role (paid or unpaid) outside of USC that interferes, appears to interfere or has the potential to interfere with the USC Employee’s ability to perform core job responsibilities and commitments to USC.
Conflict of InterestThe term Conflict of Interest encompasses both Conflicts of Interest and Conflicts of Commitment. A Conflict of Interest arises when:Professional, financial, or personal activities or relationships compromise, or have the appearance of compromising, a USC Employee’s professional loyalty and responsibility to USC, and ability to perform USC duties and responsibilities in a full and complete manner.A USC Employee’s professional, financial, or personal activities compete, or have the appearance of competing, with the university.See sections Prohibited Conflicts of Interest and Outside Activities and Conflict of Commitment.
Employment or Academic Decision Includes decisions relating to initial appointment or hire, retention, termination, reappointment, non-reappointment, evaluation, promotion, compensation, benefits, leave of absence or decisions on admission, grades, or academic advancement.
Financial ActivitiesActivities in which a USC Employee receives salary, royalty, intellectual property rights, consulting fees, ownership interest (e.g., stocks, stock options or other ownership interest, excluding diversified mutual funds), or other financial benefit. Financial benefits are usually associated with roles such as employment, management positions, independent contractor engagements (including contracted research), consulting, speaking and teaching, membership on advisory committees or review panels, board membership, and other activities from which remuneration is received or expected.
HonorariumFor the purposes of this policy, an honorarium is a payment for services. This method of payment is usually made to a guest speaker or lecturer as a “thank you” and gesture of good will and appreciation.
Personal RelationshipIncludes relationships of a romantic or intimate nature as well as other relationships that may give the appearance of a Conflict of Interest.

5. Policy Details

  • USC Employees must disclose any relationship, outside activity, and/or Financial Activity that creates an actual or potential Conflict of Interest to their supervisor, department chair, or Dean and via diSClose to the Office of Culture, Ethics and Compliance.
  • Supervisors, department chairs, or Deans who become aware that USC Employees under their supervision have a reportable Conflict of Interest must instruct the Employee to report the conflict through diSClose.
  • The Office of Culture, Ethics and Compliance will review the reported disclosure and engage with the USC Employee’s supervisor, department chair, or Dean to approve the activity or develop a management plan, if needed. If the Conflict of Interest is prohibited under this policy, the employee will be required to terminate the activity giving rise to the conflict.
  • If there are varying positions on how to resolve the Conflict of Interest, the Office of Culture, Ethics and Compliance may escalate the disclosure to the Conflict of Interest Committee for recommendation on the appropriate course of action to address and mitigate the conflict.
  • The reported activity may only proceed after the responsible supervisor, department chair, or Dean and the Office of Culture Ethics and Compliance approve the activity or relationship, and the USC Employee takes the required steps to mitigate and/or eliminate the conflict.
  • The approval of a disclosed Conflict of Interest is subject to ongoing review. USC Employees must immediately update their supervisor, department chair, or Dean and the Office of Culture, Ethics and Compliance regarding any changes to activities previously disclosed under this Policy.

Prohibited Conflicts of Interest

In general, all USC Employees must avoid any of the following unless the activity or relationship in question is disclosed to and expressly approved by the USC Employee’s supervisor, department chair, or Dean AND the Office of Culture, Ethics and Compliance:

  • Engaging in a Financial Activity with a USC competitor, supplier, or customer.
  • Having any role in an Employment or Academic Decision that involves a direct benefit or detriment to a USC Employee, student or independent contractor who is a Close Relation.
  • Engaging in outside activities that influence one’s ability to make decisions in the best interest of USC or involve a time commitment that interferes with a USC Employee’s job duties and core schedule at USC (see Outside Activities and Conflict of Commitment for additional information).
  • Accepting a business opportunity learned of in the course of employment with USC that also represents an opportunity for USC.
  • Using university resources or supplies (except for incidental use) outside the scope of a USC Employee’s employment (e.g., in support of personal business ventures) without the express written approval of the Provost (for faculty), or the Senior Vice President, Administration (for staff), or their designees
  • Any action that may seem to commit USC to an endorsement (e.g., of a business, private practice, commercial product, or political position) unless expressly authorized in advance by the Provost or his or her designee.
  • Holding tenure simultaneously at two institutions, unless specially authorized by the President of USC.
  • Holding an untenured faculty appointment at another institution as well as a USC appointment, unless doing so in connection with an approved leave, or approved educational work, or as otherwise approved by the Provost.
  • For faculty, employing or seeking to employ or otherwise utilize a student’s services in connection with a business venture when the faculty member has an academic or advising relationship with the student.

Outside Activities and Conflict of Commitment

USC recognizes that USC Employees may want to hold additional jobs or be involved in business and community relationships outside their employment with USC.

USC Employees must carefully consider the demands that outside activities will create before accepting outside employment or other outside engagements. Outside employment or other engagements that compete with USC, interfere with performance of job responsibilities, or involve a time commitment that conflicts with availability to perform work for USC, must be disclosed to the employee’s supervisor, department chair, or Dean and the Office of Culture, Ethics and Compliance before the activity is undertaken. 

USC Employees may not engage in any outside activity that requires regular or extensive absence from USC during times when the USC Employee is required or expected to perform assigned duties and responsibilities. This policy does not impact an employee’s ability to seek or request various leaves of absences under other policies. 

If outside activity causes or contributes to job-related problems and/or performance-related issues, the USC Employee will be required to discontinue the outside activities and may be subject to discipline under existing USC policies.

Outside activities of faculty must comply with the provisions of this policy and adhere to the related sections of the USC Faculty Handbook, as well as the Conflict of Interest in Research and/or Relationships with Industry policies, as applicable.

Honorarium received by USC Employees based on their role at USC and in conjunction with their external professional activities is not considered an outside activity for the purpose of this policy. Honorarium that creates an actual or perceived Conflict of Interest must be disclosed to a USC Employee’s supervisor, department chair, or Dean and reported through “diSClose”. The applicable requirements of the Conflict of Interest in Research Policy must also be followed.

Handling of Conflicts of Interests related to Close and Personal Relationships

A USC Employee may not work directly for or supervise a Close Relation. This also applies to Close Relations where no line of authority or reporting is involved, but where the relationship may create an actual or potential Conflict of Interest, in which case it must be disclosed to determine if the Conflict can be managed.

Supervisors, department chairs, and Deans are prohibited from dating or having a romantic or intimate relationship with a subordinate (and vice versa) and may face corrective action for doing so, up to and including termination.

Further, USC expressly prohibits Personal Relationships between faculty, staff (including student advisors) and undergraduate and graduate students where there is a supervisorial, advisory, or evaluative relationship between them without written approval from the Provost or the Senior Vice President for Human Resources, Equity and Compliance.

USC reserves the right to take prompt action if an actual or potential Conflict of Interest arises, based on a USC Employee’s close or personal relationship, that may affect the terms and conditions of employment of a USC Employee.

Monitoring

Management plans may be put in place to mitigate identified Conflicts of Interest. Examples of management plans include additional monitoring and oversight, periodic updates on approved activities, limitations on activities that may contribute to a Conflict of Interest becoming a higher risk to USC, or recusal from involvement on decisions where a conflict exists. Termination of the relationship in question may also be required if it creates a Conflict of Interest that cannot be successfully mitigated.

Violations

Violations of this policy are considered misconduct on the part of a USC Employee, who may be subject to established disciplinary procedures. Violations include but are not limited to situations in which:

  • A USC Employee knows of a situation that places the employee in a potential or actual Conflict of Interest or Conflict of Commitment but fails to disclose it fully, according to the policies of USC.
  • A USC Employee discloses a potential or actual Conflict of Interest or Conflict of Commitment but fails to abide fully by the required plan for avoiding or managing the conflict.

6. Procedures

USC Employees must disclose actual, potential, or perceived Conflicts of Interest through disclose.usc.edu.  

7. Forms

N/A

8. Responsibilities

POSITION or OFFICERESPONSIBILITIES
USC EmployeesAvoid activities or relationships that might affect their objectivity in making decisions on behalf of or for USC.Identify, disclose, and discuss actual or potential Conflicts of Interest with their supervisor, department chair, or Dean.Identify and report potential Conflicts of Interest to the Office of Culture Ethics and Compliance using diSClose.Obtain necessary approval on reported Conflicts of Interest and adhere to management of Conflict of Interest plans.Report any material changes in previously reported and approved Conflicts of Interest.Update their disclosures promptly upon any changes to the relationship or financial interest disclosed.
Management/Supervisors, department chairs, and DeansHelp USC Employees identify and report potential Conflicts of Interest.Work with the Office of Culture, Ethics and Compliance to review reported Conflicts of Interest and determine appropriate course of action.For approved Conflicts of Interest and when required, create a Conflict of Interest Management Plan in consultation with the Office of Culture, Ethics and Compliance.Instruct employees to follow Conflict of Interest management plans that apply to them.Execute any portion of the Conflict of Interest management plan as it relates to their management and supervisory obligationsInstruct employees under their supervision to promptly notify the Office of Culture, Ethics and Compliance of any changes to the previously reported Conflicts of Interest and/or the provisions of the Conflict of Interest management plan.Notify the Office of Culture, Ethics and Compliance of any violations of the Conflict of Interest management plan
Human ResourcesPartner with management, supervisor, department chair, or Dean and the Office of Culture, Ethics and Compliance to address reported and identified Conflicts of Interest.Provide guidance and direction on Conflicts of Interests that fall under the authority of Human Resources.
The Office of Culture, Ethics and ComplianceProvide guidance on requirements and applicability of the Conflict of Interest Policy.Partner with management, supervisor, department chair or Dean, Human Resources and other involved parties to address reported and identified Conflicts of Interest.

9. Related Information

10. Contacts

Please direct any questions regarding this policy to:

OFFICEPHONEEMAIL
Office of Culture, Ethics and Compliance213-740-8258compliance@usc.edu