… have any external affiliations, activities, and/or interests with any foreign entities, organizations, or institutions that are related, or reasonably appears to be related, to your Institutional Responsibilities at CU ǸԹ, including, but not limited to: - Ownership interests in the entities (e.g. equity, stock or stock options);
- Monetary or non-monetary value received from the entities or activities, including research collaborations with the intent to publish (e.g. any salary; consulting fees; speaking engagement fees or reimbursements; payments for services; honorary titles; free or subsidized use of space/offices/labs, equipment, or support services including visiting researchers or other personnel; intellectual property rights or royalties; or reimbursed/sponsored travel or other payments);
- Obligations to the entities or arising from the activities (e.g., teaching or research appointments; invitations or appointments to consult in foreign talent recruitment programs; transfer of intellectual property);
THEN ... | - ... disclose theactivity in your annual Disclosure of External Professional Activities ("DEPA") Form.
- ... update your DEPA Form within 30 days of a status change.
- ... disclose to and receive approval from your Supervising Authority, (e.g. Department Chair or Institute Director).
- ... follow the University of Colorado's and any Department policies and procedures related to dual appointments at other institutions.
- ... refrain from using University facilities/space to privately benefit you or an Entity with whom you have a Significant Interest, unless you have first disclosed the Significant Interest and obtained written approval from your Supervising Authority and a written lease agreement from university Real Estate Services.
- ...refrain from diverting contracts/opportunities or using other University resources to privately benefit you or an Entity unless you have first disclosed the Significant Interest and obtained approval from your Supervisor and a written agreement from an authorized and disinterested University official.
- ...notify your Office of Contracts and Grants (“OCG”) Proposal Analyst.
- ...disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor.
- ...disclose the relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors as well as annual reports as required by the sponsor.
- ...contact the Office of Export Controls (“OEC”) for review to ensure the associated activity does not violate U.S. open research standards, illicitly further technology in other countries using U.S. federal funding, etc.
| Contact theOffice of Conflicts of Interest & Commitment ("COIC") via email at coi@colorado.eduorby phone at (303) 492-3024. - COIC should be contacted prior to beginning any new engagements in order to assess the need for any actual and/or perceived conflicts.
- COIC will review and screen Significant Interests disclosed via the DEPA Form, and, if applicable, a Management Plan will go into effect in order to manage the Conflict of Interest and/or to prevent a Significant (Financial) Interest from ripening into a Conflict of Interest.
- Contact the Office of Export Controls ("OEC") via email at exportcontrolshelp@colorado.edu.
- Refer to the Office of Contracts and Grants website for disclosure information, toolsand contacts, such as: Disclosing Other Support webpage.
- Contact Venture Partners via email at vpcontact@colorado.edu.
For more information, please visit the following COIC webpages: |
| ... have been invited to participate or are currently participating in a foreign talent recruitment program, THEN ... | - ... disclose the finalized activity in your annual DEPA Form.
- ... update your DEPA Form within 30 days of a status change.
- ...disclose to and receive approval from your Supervising Authority.
- ...follow the University of Colorado’s and any Department policies and procedures related to dual appointments at other institutions.
- ...notify your OCG Proposal Analyst.
- ...disclose the relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors.
- ...decline to participate if you have a contract to work with Huawei or a subsidiary of (currently, CU ǸԹ willin a Department of Energy (DoE) national lab.
- ...contact OEC for review to ensure the associated activity does not violate U.S. open research standards, illicitly further technology in other countries using U.S. federal funding, etc.
| |
| … have been invited to work with Huawei or a subsidiary of Huawei, THEN… | - ... disclose to your Supervising Authority.
- ... decline to work withHuawei or a subsidiary of (currently, the University will not accept funding from Huawei or subsidiaries of).
| The Research & Innovation Office (“RIO”) keeps up-to-date on any developments in federal guidelines and regulations regarding debarment of foreign sponsors. |
| … have travel reimbursed or sponsored by a foreign entity, individual, or government, THEN … | - ... disclose the activity in your annual DEPA Form.
- ... update your DEPA Form within 30 days of a status change.
- ...disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor.
- …contact OEC to discuss export control-related concerns for international travel.
- ... comply with CU ǸԹ travel processes and policies (including any travel policies your Department/Institute may have); submit the trip through Concur; and, for international travel, complete an international export control travel form.
| - Contact COIC via email at coi@colorado.edu.
- Contact OEC via email at exportcontrolshelp@colorado.edu.
- OEC provides essential information regarding international travel that should be reviewed prior to travel.
- OEC has laptops available for researchers to borrow for CU ǸԹ-related international travel.
- For more information, please visit the International Travel section of the Export Controls webpage.
- Refer to the Office of Contracts and Grants website for disclosure information, toolsand contacts, such as:Disclosing Other Support webpage.
|
| … have a foreign entity propose an institutional partnership with CU ǸԹ and/or a consulting relationship with you, THEN … | - ... disclose the finalized activity in your annualDEPA Form.
- ... update your DEPA within 30 days of a status change.
- ... disclose to and receive approval from your Supervising Authority.
- ... contact your OCGProposal Analyst.
- … disclose to your sponsor(s), as required by the terms and conditions of your award.
- ...disclose the proposed relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors.
| - RIO works closely with the Global Engagement Office to support international activities that are critical to the CU ǸԹ mission.
- Contact COIC via email at coi@colorado.edu.
- Contact OEC via email at exportcontrolshelp@colorado.edu.
- Refer to the Office of Contracts and Grants website for disclosure information, toolsand contacts, such as:Disclosing Other Support webpage.
- Contact Venture Partners via email at vpcontact@colorado.edu.
|
| … have an active or proposed position, have been provided funding, or have a foreign research collaborations (funded or not) with a foreign institution,THEN … | - ... disclose the finalized activity in your annual DEPA Form.
- ... update your DEPA Form within 30 days of a status change.
- ... follow the University of Colorado's and any Department policies and procedures related to dual appointments at other institutions.
- ... contact OEC to discuss export control concerns.
- ... disclose to your sponsor(s), as required by the terms and conditions of your award and in annual reports as required by the sponsor.
- ...disclose the (proposed) relationship in grant proposal biosketch and current and pending documents on proposals to federal sponsors.
| |
| … have any external affiliations, activities and/or interests with any foreign entities, organizations or institutions that are related, or reasonably appear to be related, to your Institutional Responsibilities at CU ǸԹ AND have funding from the Department of Defense (DoD) or Department of Energy (DoE), THEN … | - ... disclose theactivity in your annualDEPA Form.
- ... update your DEPA Form within 30 days of a status change.
- ... contact OCG prior to starting any international collaboration (related to the research or otherwise).
| - Contact COIC via email at coi@colorado.edu.
- Contact your OCG Proposal Analyst.
- DoD and DoE have specific clauses that may limit international collaboration.
|
| … have ownership interest in a foreign company,ձᷡ… | - ... disclose the finalized activity in your annual DEPA Form.
- ... update your DEPA within 30 days of a status change.
- ... disclose the relationship in biosketch and current and pending documents on proposals to federal sponsors (if applicable) and in annual reports as required by the sponsor.
| |
| … plan to host or do host a visiting scholar, student, tour group or other individual from a foreign entity, THEN … | - ... disclose the finalized activity in your annual DEPA Form.
- ... update your DEPA within 30 days of a status change.
- ... disclose to and receive approval from your Supervising Authority.
- ... contact OEC to review intended locations to be visited, verify if any restrictions apply and vet individuals who will be visiting.
| |
| … anticipate a project that is classified and/or involves controlled unclassified information ("CUI"), THEN … | - ... disclose the finalized activity in your annual DEPA Form.
- ... update your DEPA within 30 days of a status change.
- ... disclose to and receive approval from your Supervising Authority.
- ... contact the OCG Research Security team.
- ... contact the CU ǸԹ Research Cyber Security Program for CUI research.
| - Contact COIC via email at coi@colorado.edu.
- Contact OCG Research Security team via email at cufso@colorado.edu.
- Contact CU ǸԹ Research Cyber Security Program via email at scott.maize@colorado.edu.
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