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What if I have a financial interest in a contract with the University in an area that doesn’t relate at all to my research or work for the University?

State law makes it a felony for IU employees to knowingly or intentionally have a personal financial interest in, or derive a profit from, “a contract or purchase connected with an action by [the University],” unless certain exceptions apply.

Under state law, “employee” means not only the employee, but also the employee’s spouse, children under 18 who are still at home, and any other “dependent,” which means anyone for whom the employee provides more than half of their annual financial support. This means that IU employees must consider not only their own benefits from a University contract or purchase, but also any financial benefits gained by their spouse, minor children, and dependents, in determining whether or not the state conflicts law applies to their circumstances.

The law contains certain exceptions to the general prohibition against University employees having a personal financial interest in a University contract or purchase. First, there is an exception for employees whose financial interest in a University contract or purchase is de minimis. To be de minimis, the employee’s financial interest in a University contract or purchase, added together with any financial benefit(s) they had in any other University contracts or purchases for the preceding 12 months, must total less than $250.

Second, there is an exception when employees disclose in writing to the Board of Trustees their financial interest in a proposed contract or purchase, before final action is taken on the contract or purchase, and the Board approves the circumstances. Disclosures must be made on the State Conflicts Disclosure form.

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