UNIVERSITY OF VIRGINIA
          FINANCIAL AND ADMINISTRATIVE PROCEDURES MANUAL



TITLE:  PROVIDING NOTICE OF POSSIBLE              PROCEDURE:  15-1
        CONFLICT OF INTERESTS                                      
                                                                   

Policy Reference:              XV.A.1

Purpose

To provide a means of notification of an actual or potential
conflict of interests affecting contracts or transactions to which
the University is a party or in which the University's interests
may be affected.

Background

The employee should address a letter to the appropriate department
head covering the following points:

     The nature of the employee's "personal interest" in the
     contract or transaction.

     The employee's authority, if any, to participate in contracts
     or transactions on behalf of the University.

     The measures taken to comply with State requirements for
     competitive procurement.

     Any permissions or opinions obtained from the Attorney
     General.

A copy of the contract and other related documents in question
should be attached.

NOTE:  The Office of the University General Counsel's Office is not
authorized to give personal legal advice to employees; advice from
the General Counsel's Office must relate to University legal
issues.  Therefore, an employee with an actual or potential
conflict of interests should also consider contacting his/her
personal attorney for advice.

Instructions

Process as indicated.

Special Procedure for Research and Development Contracts

Effective July 1, 1991, the Virginia State and Local Government
Conflict of Interests Act (Section 2.1-639.6) was modified to
exempt certain research and development contracts from categories
of previously prohibited contracts.

Special Procedure for Research and Development Contracts, cont'd.

The modification allows an employee to have a "personal interest"
in a research and development contract with the University so long
as the following conditions are satisfied:

     The University has established a formal policy regarding such
     contracts, approved by the State Council of Higher Education;

     The employee's personal interest has been disclosed to and
     approved by the University prior to the time the contract is
     entered into; AND

     The employee has filed a "Statement of Economic Interests"
     annually before January 15 of each succeeding year.

The definition of "personal interest" is set forth in Financial and
Administrative Policy XV.A.1, and copies of the Statement of
Economic interests are available from the Office of the Assistant
Vice President for Finance and University Comptroller.

At the time a proposal for sponsored research is submitted for
University review and approval, the employee shall indicate on the
Proposal Approval Sheet that the employee has a personal interest
in a firm, corporation, partnership, or other business entity which
is a party to the proposed contract with the University.  That
personal interest shall be disclosed in writing to the employee's
department chair and dean.  If the chair and dean determine that
the contract is in the best interests of the University, they shall
so affirm in writing and recommend to the Associate Provost for
Research (APR) that the University accept the contract.  If review
by the APR also indicates that the contract is in the best
interests of the University, the APR shall so affirm in writing and
recommend to the Assistant Vice President for Finance and
University Comptroller (AVPF) that the University accept the
contract.  Upon notice of final approval of the contract by the
AVPF, the employee shall then promptly file a "Statement of
Ecomonic Interests" with the AVPF, and the employee shall file this
statement annually thereafter on or before January 15 for the
duration of the contract.

For the duration of the contract and on each subsequent renewal,
the department chair, dean, and APR should determine that the
contract continues to be in the best interests of the University.

Decisions made by the department chair, dean, APR, and the AVPF may
be appealed to the appropriate academic Vice President whose
decision shall be final.  (Approved by SCHEV on February 3, 1992)

    Responsibility                          Action                 

Employee                    1. Addresses a letter to his/her
                               department head describing the
                               situation and requesting approval
                               for his/her participation.

                            2. Forwards letter, a copy of any
                               related contract or subcontract, and
                               all supporting documents to the
                               department head.

Department Head *           3. Reviews material forwarded from
                               employee.

                            4. Endorses the employee's letter
                               recommending approval or
                               disapproval.

                            5. Forwards all material:

                               5a.  If approval is recommended, to
                               the Assistant VP for Finance and
                               Univ Comptroller.

                               5b.  If disapproved, to employee.

Assistant VP for Finance 
and Univ Comptroller        6. Reviews material forwarded from
                               department head.

                            7. Contacts University General Counsel
                               if assistance is needed.

                            8. Approves or disapproves.

                            9. Notifies department head of action
                               taken.

                           10. Directs request packet to the
                               appropriate office for filing in
                               contract file, personnel file, etc.

* NOTE: For research and development contracts, the appropriate
dean and the Associate Provost for Research shall also be involved
in the review process.

                                                                   
ISSUED BY:                                                 08/01/92

Assistant VP for Finance
and University Comptroller     15.1.3