Home

III-8 Conflict of Interest in Employment (Nepotism)

(Regents 4/20/77; approved Faculty Senate 4/95; Staff Executive Council 7/95; President 9/95; amended 12/04; 4/17; 7/1/17; 1/14/21; 4/1/25)

Effective April 1, 2025, this policy has been revised. For the most current version without redlining, return to III-8.

Note: This chapter is one of several that address conflicts of interest of various types at the University of Iowa. Others include: II-5 Consensual Relationships Involving Students, which addresses faculty-student relationships that are either prohibited or discouraged due to role conflicts; and II-18 Conflicts of Commitment and Interest, which addresses time conflicts, role conflicts in the workplace, and financial conflicts of interest. See also II-18.8 Other University of Iowa Policies Related to Conflict of Interest for a complete list of policies that address or are related to conflicts of interest.

8.1 Rationale

(Amended 4/1/25)

It is the policy of the university that conflicts of interest must be avoided where possible, and otherwise disclosed and managed. The University of Iowa and its employees are committed to the principle of objective, fair, and equitable treatment of all employees. Accordingly, it is crucial that university activities be conducted in an atmosphere that is free of actual or apparent potential conflicts of interest that compromise this principle. For the purpose of protecting both This policy protects the integrity and objectivity of its university employees in the performance of their university obligations, and to create supports a workplace environment based in equity and fairness, it is the policy of the university that conflicts of interest should be avoided where possible, and otherwise disclosed and managed. Other types of conflicts of interest may be managed under university policies as listed in III-8.12.

8.2 Definitions

(Amended 4/1/25)

  1. A "conflict of interest in employment" at the University of Iowa may arises when 1) an individual University of Iowa employee has the responsibility to make, or participate actively in making, decisions or recommendations relating to the employment status of another individual University of Iowa employee (hereafter "decision-making responsibility"), or 2) there is a direct reporting line between two such individuals. and 2) these two individuals (hereafter “associated individuals”) have a current or former relationship occurring outside the work setting that would make it difficult for the individual with decision-making responsibility to be objective, or that for a reasonable person would create the appearance that such an individual may not be objective. 

    Given 1) or 2) above, a conflict of interest in employment arises whenever the two such individuals (hereafter, "related individuals") have a current or former relationship occurring outside the work setting that would make it difficult for the individual with the decision-making responsibility to be objective, or that for a reasonable person would create the appearance that such an individual may not be objective.
  2. “Decision-making responsibility” includes but is not limited to situations when there is any  reporting line between two associated Individuals. For the purposes of these rules, decisions or recommendations related to employment status include those related to hiring, salary, and resource allocation, including grant funding, working conditions, working responsibilities, evaluation, promotion, and termination.

    Examples of relationships that give rise to “associated individuals” include, but are not limited to, the following:
    1. relationships by blood, adoption, marriage, or domestic partnership: partner, parent, child, sibling, first cousin, uncle, aunt, nephew, niece, spouse, brother- or sister-in-law, father- or mother-in-law, son- or daughter-in-law, step-parent, or step-child; or
    2. romantic and/or sexual relationships or intense personal friendships or conflicts; or
    3. significant business relationships.
  3. For purposes of these rules, decisions or recommendations related to employment status include those related to hiring, salary, working conditions, working responsibilities, evaluation, promotion, and termination.
  4. For purposes of these rules this policy, the phrase "first neutral supervisor" means is the person (usually the director, departmental executive officer, divisional head, dean of the college, or vice president in charge of the department, college, or unit) immediately superior to the one of the two related associated individuals who, if there were no conflict of interest, would have decision-making responsibility relating to the employment status of the other related associated individual. 
  5. For purposes of this policy, the “university official” is the university administrator who has primary responsibility for approval of employment decisions regarding the associated individuals, and is typically the dean or vice president, or their designee, who holds administrative responsibility for the college or organizational unit in which the associated individuals are employed.

8.3 Policy

The decision to manage a conflict of interest in employment rather than avoid it must be based on a sound institutional reason. The collegiate or other major unit officer(s) (typically a dean or vice president, or designee) having primary responsibility for approval of employment-status decisions regarding the related individuals also has/have the responsibility of determining whether such a reason exists. If such a reason exists, related individuals can be employed, or can continue to be employed, by the university only if a management plan is developed as described in III-8.6 below.

An individual is not deemed to have decision-making responsibility (and therefore no conflict of interest in employment exists) if that individual's participation is limited to routine approvals and the individual plays no role involving the exercise of any discretion in the decision-making processes. The collegiate or other major unit officer(s) (typically a dean or vice president, or designee) having primary responsibility for approval of employment-status decisions regarding the related individuals also has/have the responsibility for determining whether a conflict of interest in employment exists.

If any question arises whether an individual's participation is greater than is permitted by this section, the Committee on Conflict of Interest in Employment ("Committee") should be consulted for its consideration and recommendation (see III-8.9 below). 

8.3 Scope of Policy

(Amended 4/1/25)

These provisions apply to full-time, part-time, regular, and temporary faculty and staff, and student employees and persons with fellowships which involve employment at the university who meet the definition of associated individuals, as defined in III-8.2, at any time during their employment or when they seek employment at the university.

In cases where the individual over whom the other individual has responsibilities to make decisions or recommendations related to employment is compensated in the amount of $1,800 or less in any fiscal year, a formal management plan is not required but responsibility for approving employment matters, including time records, must be assigned to an alternative, non-conflicted supervisor.

8.4 Occasional or Irregular Conflicts of Interest

If a conflict of interest in employment is occasional or irregular (e.g., a tenure or promotion vote), recusal is an acceptable and necessary mechanism for managing the conflict. In such cases, a written statement by the person having the decision-making responsibility that they will recuse themselves from any employment-related decisions pertaining to the other individual is desirable, but not required. 

8.4 Committee on the Conflict of Interest in Employment

(Amended 4/1/25)

The Committee on Conflict of Interest in Employment (“Committee”) will review and consider for approval management plans that are developed as described below. The Committee may approve or deny proposed management plans.

The Committee shall consist of four members appointed by the Faculty Senate and three members appointed by the Staff Council. Members of the Committee shall be appointed for staggered three-year terms, but no person may be appointed for more than two consecutive terms. The Associate Provost for Faculty and the Chief Human Resources Officer or their designees shall serve as co-chairs of the Committee. Committee members shall not participate in the development and approval of a management plan or the oversight of a management plan if a) they are related to either of the associated individuals; b) they participated in the development of the management plan in their unit of employment; c) their conditions of employment could be affected by a management plan; or d) some other conflict of interest exists. Decisions of the Committee shall be made by majority vote of the Committee members voting on the decision. 

All meetings and deliberations of the Committee shall be confidential.  All written materials reviewed or created in the development of a management plan shall be confidential. One of the Committee's co-chairs shall keep on file the Committee's official copy of all management plans. Any information disclosed by either of the associated individuals for the purpose of developing the management plan shall be used solely for that purpose. However, faculty, staff, and students who are in positions to be affected significantly by a conflict of interest in employment  (typically, others who interact  directly with the associated individuals in the context of their work) shall be informed of the existence of the management plan and shall be provided with information regarding the appropriate person(s) to whom they may bring relevant concerns. In most cases, this will be the first neutral supervisor for faculty and staff, although departmental human resource representatives or the Director of Undergraduate or Graduate Studies may be the more appropriate person for staff and students, respectively, in some units.

8.5 Identification of and Initial Steps to Address Conflicts of Interest in Employment

(Amended 1/14/21)

If the conflict of interest in employment is not occasional or irregular but is ongoing so that recusal is not a reasonable mechanism for managing the conflict, other mechanisms (see https://hr.uiowa.edu/policies/conflict-interest-employment) must be adopted. The process to manage the conflict is initiated by notification of the relationship. Ideally, both related individuals should bring the existence of the relationship to the attention of the first neutral supervisor. However, as soon as one of the related individuals does so, the first neutral supervisor shall begin to develop a management plan. For relationships that develop between persons already in a supervisory relationship or when an organizational change results or would result in a supervisory relationship between two related individuals, disclosure should be made at the earliest possible date and no later than within ninety days after commencement of the conflict of interest situation. In addition, faculty and staff who submit an online Annual Disclosure of Outside Professional Activities and Interests in the eCOI system as outlined in II-18.5.e(5) will be asked to indicate whether they have a personal relationship with another University employee over whom they exercise decision-making authority. 

To deal with situations in which a conflict of interest might arise through a hiring decision, a management plan must be developed such that the hiring process itself is conducted free of any actual or apparent conflicts of interest. In such cases, disclosure of the relationship should be made at the earliest possible point, in many cases even before the related individual applies for the position. 

8.5 Policy

(Amended 4/1/25)

It is the policy of the university that conflicts of interest must be avoided where possible. The decision to manage a conflict of interest in employment rather than avoid it must be based on a sound institutional reason. The university official as defined in III-8.2 has the responsibility of determining whether such a sound institutional reason exists. If such a reason exists, associated individuals can be employed, or can continue to be employed, by the university only if a management plan is developed, approved, and implemented as described in III-8.8 below.

An individual is not deemed to have decision-making responsibility (and therefore no conflict of interest in employment exists) if that individual's participation in employment-related decisions affecting the other associated individual is limited to routine approvals and the individual is not required to exercise  discretion in the decision-making processes. The university official as defined in III-8.2 has the responsibility for determining whether a conflict of interest in employment exists. If any question arises whether an individual's participation is greater than is permitted by this section, the Committee should be consulted for its consideration and recommendation (see III-8.3 above). 

Where the associated individual with decision-making responsibility is a dean, vice president, other member of the President’s cabinet, or head coach, the Committee must approve the university official’s determination as to whether a conflict of interest in employment exists, and whether a sound institutional reason exists to manage the conflict. Once determined, the Committee must review and approve the proposed management plan as outlined in III-8.8 below.

8.6 Management Plans

  1. As soon as notification of an actual or potential conflict of interest in employment has been received, the first neutral supervisor must develop a management plan by which the one related individual with the decision-making responsibility is removed from the decision-making processes that affect the employment status of the other related individual. If all the relevant individuals desire, a neutral supervisor superior to the first neutral supervisor may develop the management plan. If the conflict of interest might arise through a hiring decision, then the hiring process itself should be included in the management plan.

    A template describing the elements of a management plan is available at https://hr.uiowa.edu/policies/conflict-interest-employment. In addition, the co-chairs of the Committee on the Conflict of Interest in Employment (see III-8.9 below) are available for consultation regarding development of a management plan.
  2. The development of a management plan itself should not involve the participation of the related individuals except as provided by paragraph a above.
  3. The plan developed to manage the conflict of interest in employment of related individuals shall be submitted to the Committee on Conflict of Interest in Employment, after review by the dean, director, or vice president, as appropriate.
  4. The Committee shall review the proposed management plan and make recommendations on its use based upon its evaluation of the management plan's probable effectiveness in managing the conflict of interest in employment. The Committee's evaluation will include but not be limited to consideration of the plan's effectiveness in providing for objective decision making, creating and maintaining an atmosphere of equity and fairness, providing consistency in the treatment of employees, and allowing for the effective and efficient operation of the unit(s) in which the related individuals are employed. Where appropriate, the Committee also may recommend modifications to or rejection of the proposed management plan.
  5. The recommendations of the Committee shall be made to the university officer having responsibility for final approval of the employment-status decision. This officer shall make the decision concerning implementation of the management plan. If that officer is involved in the conflict of interest, the decision will be made by the President or the Board of Regents as appropriate.
  6. The Committee shall evaluate, periodically as it determines, or upon request of any individual who believes they are affected adversely by the management plan, the effectiveness of the established plan created to manage the conflict of interest in employment. The Committee's evaluation and recommendations for continuations, revisions, or rejection of the management plan shall be submitted to the vice president or other official who approved the implementation of the plan.

8.6 Occasional or Irregular Conflicts of Interest

(Amended 4/1/25)

If a conflict of interest in employment is occasional or irregular (e.g., a tenure or promotion vote), there must be a mechanism in place for managing the conflict. Recusal typically is required in any situation that involves a discussion and/or decision that could result in a direct benefit to an associated individual. In such cases, the disclosure and recusal or other management plan must be documented.

8.7 Scope of Policy

These provisions apply to related individuals whose relationship is current or former when these rules are adopted or at the time they seek employment by the university, or arises after the date of their employment by the university.

This policy applies to both full-time and part-time, regular and temporary faculty and staff, and to students and persons with fellowships which involve employment at the university. It does not apply, however, in cases where the individual over whom the other individual has responsibilities to make decisions or recommendations related to employment is compensated in the amount of $1,800 or less in any fiscal year.

(Note: This policy applies only to employment relationships. Romantic and/or sexual relationships between faculty and students in the instructional context are governed by II-5 Policy on Consensual Relationships Involving Students.)

8.7 Identification of and Initial Steps to Address Conflicts of Interest in Employment

(Amended 1/14/21; 4/1/25)

  1. If the conflict of interest in employment is not occasional or irregular but is ongoing so that recusal is not a reasonable mechanism for managing the conflict, other mechanisms (see https://hr.uiowa.edu/policies/conflict-interest-employment) must be adopted. The process to manage the conflict is initiated by notification of the relationship. Both associated individuals must notify the first neutral supervisor of the relationship. As soon as one of the associated individuals does so, the first neutral supervisor must comply with the process outlined below and document the outcome of each required step.
    1. Consult with the appropriate university official, as defined in III-8.2, to evaluate whether an actual or potential conflict of interest in employment exists.
    2. If no actual or potential conflict of interest in employment is found, notify the associated individuals of the decision and that no further action is needed.  If an actual or potential conflict of interest in employment is found, consult with the appropriate university official as to whether a sound institutional reason exists to manage the conflict.
    3. If a sound institutional reason is found to manage an actual or potential conflict of interest in employment, develop a management plan (see III-8.8) in consultation with their senior human resources representative and/or associate dean following the process set forth in III-8.8 below. If no sound institutional reason can be identified to manage an actual or potential  conflict of interest in employment, the conflict must be avoided following the process set forth in III-8.9 below.
  2. For relationships that develop between associated individuals  already in a supervisory relationship or when an organizational change results or would result in a supervisory relationship between two associated individuals, disclosure must be made at the earliest possible date and no later than twenty business days after identification of the conflict of interest. In addition, faculty and staff who submit an online Annual Disclosure of Outside Professional Activities and Interests in the eCOI system as outlined in II-18.5.e(5) will be asked to indicate whether they have a personal or external business relationship with another university employee over whom they exercise decision-making authority. 
  3. To deal with situations in which an ongoing conflict of interest might arise through a hiring decision, the associated individual must not be involved in discussions and/or decisions during the selection or hiring process. In such cases, disclosure of the relationship that might give rise to a conflict of interest in employment must be made at the earliest possible point, in many cases even before the associated individual applies for the position. 
  4. University administrators or supervisors who become aware of an actual or potential conflict of interest in employment must refer the matter to the first neutral supervisor or the appropriate Senior HR Leader in the unit where the conflict exists.

8.8 When a Management Plan Cannot Be Developed

The development of a plan to manage a conflict of interest in employment should proceed expeditiously. In the event that an acceptable management plan cannot be developed, despite diligent efforts on the part of the first neutral supervisor or other designated person, within 6 months of the notification of the relationship of the related individuals, one of them must give up their position at the university (preferably through transfer) not later than 1 year after notification of the conflict. 

8.8 Management Plans

(Amended 4/1/25)

  1. A management plan will ensure that the associated individual with decision-making responsibility is removed from the decision-making processes that affect the employment status of the other associated individual.  In addition, the management plan must include the sound institutional reason to manage, rather than avoid, the conflict .

    A template describing the elements of a management plan is available at https://hr.uiowa.edu/policies/conflict-interest-employment. In addition, the co-chairs of the Committee on the Conflict of Interest in Employment (see III-8.3 above) are available for consultation regarding development of a management plan.
  2. A neutral supervisor superior to the first neutral supervisor may develop the management plan.
  3. The associated individuals may be consulted by the department in developing a management plan, but the department is responsible for the final development of a management plan. The associated individuals must sign the management plan document to acknowledge their awareness of the plan.
  4. The management plan shall be reviewed and approved by the university official as defined in III-8.2, and then submitted to the Committee.
  5. The Committee shall evaluate the proposed management plan, considering the plan’s effectiveness in providing for objective decision making, creating and maintaining an atmosphere of fairness, providing consistency in the treatment of employees, and allowing for the effective and efficient operation of the unit(s) in which the associated individuals are employed. The Committee may approve or reject the proposed management plan. If the Committee rejects the proposed management plan, the Committee will inform the department of the reasons for rejection and may make recommendations  for modifications to improve the management plan's probable effectiveness in managing the conflict of interest in employment.
  6. If the Committee recommends modifications to the proposed management plan, the recommendations shall be made to the university official as defined in III-8.2, and the unit may resubmit a modified management plan. If the Committee approves the management plan, the university official is responsible for implementation of the management plan.

The Committee shall evaluate, annually or upon request of any individual who believes they are affected adversely by the management plan, the effectiveness of the established plan created to manage the conflict of interest in employment. As part of the annual evaluation, the department will survey faculty, staff, and students who are in positions to be affected significantly by the conflict of interest in employment as to whether there are any concerns or issues related to the management plan. The Committee may recommend continuation, revisions as appropriate, or may reject continuation of the management plan. The Committee’s decision shall be submitted to the university official to oversee implementation.

8.9 Committee on the Conflict of Interest in Employment

The Committee shall consist of four members appointed by the Faculty Senate and three members appointed by the Staff Council. Members of the Committee shall be appointed for staggered three-year terms but no person may be appointed for more than two consecutive terms. The Associate Provost for Faculty and the Chief Human Resources Officer or their designees shall serve as co-chairs of the Committee. Decisions of the Committee shall be by majority vote of the Committee members voting on the decision. Committee members shall not participate in the development and approval of a management plan or the oversight of a management plan if a) they are related to either of the related individuals; b) they participated in the development of the management plan in their unit of employment; c) their conditions of employment could be affected by a management plan; or d) some other conflict of interest exists.

All meetings and deliberations of the Committee shall be confidential and all written materials reviewed by the Committee or other persons involved in the development of a management plan, shall be considered part of the personnel files of the related individuals, and also shall be confidential. One of the Committee's co-chairs shall keep on file the Committee's official copy of all management plans. Any information disclosed by either of the related individuals for the purpose of developing the management plan shall be used solely for that purpose. However, faculty, staff, and students who are in a position to be affected significantly by a conflict of interest in employment shall be informed of the existence of the management plan, and shall be provided with information regarding the appropriate person(s) to whom they may bring relevant concerns. In most cases, this will be the first neutral supervisor for faculty and staff, although departmental human resource representatives or the Director of Undergraduate or Graduate Studies may be the more appropriate person for staff and students, respectively, in some units.

8.9 When a Management Plan Cannot Be Developed, Approved, and/or Implemented

(Amended 4/1/25)

The development of a plan to manage a conflict of interest in employment should proceed expeditiously. If  a management plan cannot be developed, approved, and/or implemented within six months of the notification of the relationship of the associated individuals, one of the associated individuals must leave their position at the university (preferably through transfer) not later than one year after notification of the conflict. 

8.10 Complaints of Policy Violations

(Amended 4/17; 7/20/22)

Effective July 20, 2022, this policy has been revised. For individual changes, see the redlined version. 

All complaints regarding violations of this policy shall be referred (for faculty) to the Executive Vice President and Provost, or (for staff) to the Chief Human Resources Officer. If the Executive Vice President and Provost or the Chief Human Resources Officer receives a complaint from any source that a conflict-of-interest-in-employment relationship exists, they shall investigate the matter immediately in order to determine whether any conflict of interest in employment exists and, if so, whether a management plan is in place. Because of the sensitive nature of this type of complaint, any investigation shall only be undertaken personally by the Executive Vice President and Provost, appropriate vice president, or associate provost or associate vice president and shall not be delegated to another. If the person investigating determines that a conflict exists but that no management plan has been implemented, they shall identify the first neutral supervisor for the purpose of developing an appropriate management plan. If the person investigating determines that no such relationship exists, or that it does exist but that an appropriate management plan is in place, they shall so advise the complainant. 

8.10 Policy Violations and Complaint Process

(Amended 4/17; 7/20/22; 4/1/25)

Violations of this policy include concealing or failing to disclose one’s own conflict-of-interest relationship, willful failure or refusal to cooperate with an approved management plan, failure of a university administrator to refer a matter as described in III-8.7, or failure of a first neutral supervisor or other university administrator to implement a management plan in a timely manner as described in III-8.9.

Complaints regarding potential violations of this policy shall be referred to the appropriate Associate Dean for Faculty (for faculty), or to the Senior HR Leader or other appropriate institutional official (for staff or student employees) who shall investigate the matter immediately to determine whether any conflict of interest in employment exists and, if so, whether a management plan should be developed; or if any other of the above potential policy violations may exist. The person investigating shall document their findings and refer the matter to the appropriate university official for any necessary action. If a management plan is already in place, the university official will evaluate its effectiveness. Upon conclusion of the investigation, the person investigating shall advise the complainant that the report has been reviewed.

Violations of this policy may subject the employee to disciplinary action.

Any proposed disciplinary actions resulting from violations of this policy:

  1. by faculty members will be governed by III-29 Faculty Dispute Procedures;
  2. by staff members will be governed by applicable Regent Merit System Rules and university policies, including III-16 Ethics and Responsibility Statement for University Staff, and the applicable grievance procedures, including III-28 Conflict Management Resources for University Staff;
  3. by graduate assistants, when dismissal is sought, will be governed by the procedure for dismissal of graduate assistants (III-12.4). When sanctions other than dismissal are imposed by the dean of the employing college, a graduate assistant may appeal through those procedures established for graduate assistant employees;
  4. by students will be governed by the Code of Student Life and Accountability Procedure.

8.11 Grievances

(Amended 7/1/17; 7/20/22; 4/1/25)

Employees who are subject to a management plan and wish to challenge administrative actions that are taken pursuant to this policy may do so following the appropriate policy for their employment status: specifically, for faculty in the tenure track or any of the specialized tracks, clinical track, or research track faculty, the Faculty Dispute Procedures (III-29); for instructional track faculty, the  Instructional Faculty Policy (III-10.11); for staff, III-28 Conflict Management Resources for University Staff; for graduate assistants, the Graduate Student Employment Agreement; and for other student employees, the Grievance Procedure for Biweekly Student Employees (III-30).

8.12 Policy Violations and Resulting Disciplinary Actions

(Amended 7/1/17; 7/20/22)

Violations of this policy may include but are not limited to concealing a conflict-of-interest relationship or willful failure or refusal to cooperate with an approved management plan. Violations of this policy are deemed a serious violation of policies governing employment and may subject the employee to disciplinary action.

Any proposed disciplinary actions resulting from violations of this policy:

  1. by tenure track, clinical track, or research track faculty members  will be governed by III-29 Faculty Dispute Procedures and the portion of the procedures dealing with faculty ethics (III-29.7, III-15); and by instructional track faculty members will be governed by the Instructional Faculty Policy (III-10.11) and the grievance procedures in it;
  2. by staff members will be governed by applicable Regent Merit System Rules and university policies, including III-16 Ethics and Responsibility Statement for University Staff, and the applicable grievance procedures, including III-28 Conflict Management Resources for University Staff;
  3. by graduate assistants, when dismissal is sought, will be governed by the procedure for dismissal of graduate assistants (III-12.4). When sanctions other than dismissal are imposed by the dean of the employing college, a graduate assistant may appeal through those procedures established for graduate assistant employees;
  4. by students will be governed by the Code of Student Life and Accountability Procedure.

(See also II-18 Conflicts of Commitment and Interest.)

8.12 Other University of Iowa Policies Related to Conflicts of Interest

(4/1/25)

  1. II-4 Sexual Harassment and Sexual Misconduct
  2. II-5 Consensual Relationships Involving Students
  3. II-18 Conflicts of Commitment and Interest
  4. II-19 Acceptable Use of Information Technology Resources
  5. II-27.6 Policy on Ethics in Research
  6. II-33 Use of University Name
  7. II-27.10 University of Iowa Authorship Policy
  8. II-35 Prohibition on Giving and Receiving Gifts
  9. III-15 Professional Ethics and Academic Responsibility
  10. III-17.7 Supplemental Activities and Extra Compensation
    1. III-17.17(1) Use of University Supplies
    2. III-17.17(2) Usurpation of Universities Opportunities
    3. III-17.17(3) Royalties from Course Materials
  11. V-11 Purchasing
    1. V-11.14 Conflict of Interest
    2. V-11.15 Purchases from University Faculty or Staff
    3. V-11.22 Items Which May Not Be Purchased
  12. V-30 Intellectual Property Policy 
  13. Start-Up Company Conflict of Interest Issues/Policies: 
    http://coi.research.uiowa.edu/files/coi.research.uiowa.edu/files/docs/start_up_guide_-_revised_052012.pdf
  14. University of Iowa Health Care Conflict of Interest and Conflict of Commitment Policy:
    https://uihc.org/conflict-interest-policy