| Adoption |
| Date: November 25, 2025 Instance of Approval: Administration Committee |
| Responsible Department: Office of the Secretary General |
1. PURPOSE
1.1. The purpose of this Policy is to outline basic principles and rules to prevent or handle Conflict of Interest (as defined below) in order to protect the integrity and interests of the University of Ottawa (the “University”).
1.2 While this Policy does not, and cannot, deal with every situation that may arise, this Policy should be considered as providing a baseline for honest and ethical University decision-making.
2. APPLICATION
2.1 This Policy applies to University Members as defined in Section 3.5 where there is no other University by-law, policy, procedure, collective agreement, contract, other governing instrument or applicable law in effect, relevant to the University Member or the situation giving rise to a Conflict of Interest.
2.2 In addition to this Policy, other University by-laws, policies, procedures may apply. To the extent the provisions in another University by-law, policy or procedure are tailored to address Conflict of Interest in a specific area, or to apply to a particular group, such other tailored provisions of such other University by-law, policy or procedure will take precedence over general provisions in this Policy. Examples of University by-laws, policies, procedures, that could apply to a situation giving rise to a Conflict of Interest situation include, but are not limited to, the following (as may be amended from time to time):
a) University Board By-law No. 1 (2019) – Organizational By-law of the Board of Governors
b) University Board By-law No. 3 (2020) – Delegation of Approval of Contracts and Signing Authority
c) Board of Governors Code of Ethical Conduct
d) Regulation on the Pension Fund Investment Committee and on the Pension Plan Committee
e) Policy 36 – Procurement, Procedure 4-3 Procurement Standards and any other procurement related procedures
f) Policy 29 - Commercialization - Commercialization of Research, Procedure 29-1 Conflict of Commitment and Conflict of Interest in Commercialization of Research.
g) Policy 115 - Responsible Conduct of Research and Procedure 29-2 – Addressing Allegations of a Breach of Responsible Conduct of Research
h) Policy 10 – Fundraising and Gift Acceptance
i) University Academic Regulations (example, Academic Regulation C-7 – Thesis)
j) Faculty-specific policies and/or academic regulations.
k) APUO Collective Agreement, Article 10
2.3 Nothing in this Policy shall replace any applicable conflict of interest provisions in: 1) a collective agreement to which the University is a party; 2) any other contract to which the University is a party; 3) applicable law; or 4) a regulated profession’s code of conduct relevant and applicable to circumstances involving the University.
3. DEFINITIONS
3.1 “Conflict of Interest” means in any instance when, a University Member’s private interest interferes, or appears to interfere, with the interests of the University as a whole. A Conflict of Interest includes, but is not limited to, a situation:
a) in which financial, professional or other personal considerations or commitments compromises the University Member’s judgment in carrying out their University responsibilities objectively and effectively or take precedence over or detrimentally affect the University Member’s ability to fulfill their primary University Responsibilities; or
b) where a University Member is in a position to influence University business, activities or decisions in ways that advances their own personal interests or the interests of a Related Party to the detriment of the University’s interests or integrity; or
c) where the University Member or a Related Party has a private or personal interest in an agreement, transaction or other undertaking involving the University.
A Conflict of Interest can be an actual, perceived or a potential Conflict of Interest:
a) An actual Conflict of Interest means a situation where a University Member has a personal or private interest that is sufficiently connected to their University Responsibilities that it influences their exercise of their University Responsibilities.
b) A perceived Conflict of Interest is a situation where a reasonably informed person could properly have a reasonable belief that the University Member has an actual Conflict of Interest even where that is not the case in fact.
c) A potential Conflict of Interest means a situation where a University Member has a personal or private interest that could influence the performance of their primary University Responsibilities provided that they have not yet exercised that or those University Responsibilities.
3.2 “Head of Unit” means the University employee who holds a University position with the highest level of managerial decision-making authority of a University faculty, school or other academic unit, administrative service or other operating office of the University.
3.3 “Related Party” means,
a) a University Member’s Relative (as defined below);
b) any other individual residing in the same household as the University Member; or
c) any corporation, trust or other entity in which the University Member or their Relative has an ownership, financial, legal or beneficial or other interest.
3.4 “Relative” means a person who is related to the University Member by,
a) marriage or common law partnership, by blood relationship, by adoption, (for example, spouse or domestic partner, children, parent, sibling, grand-children, in-laws, aunt, uncle, niece, nephew);
b) other personal/close relationship that is of primary importance in their life.
3.5 “University Member” means any of the following:
a) full-time, part-time or temporary University employee,
b) University appointee (for example, University volunteers, those with a University academic or administrative appointment, adjunct, visiting, fellow or emeritus appointment),
c) anyone engaged by the University to provide services or goods to the University (for example, consultants, contractors).
3.6 “University Responsibilities” means the University Member’s duties, obligations and responsibilities to the University with respect to their employment, appointment, contractual relationship to the University or other engagement with the University.
4. GENERAL PRINCIPLES
4.1 The University is committed to maintaining the public trust and confidence in its activities.
4.2 University Members must act honestly and uphold the highest ethical standards when performing their University Responsibilities, arrange their private interests to prevent Conflicts of Interest and disclose a Conflict of Interest if it arises.
4.3 Conflict of Interest must be avoided unless permitted under this Policy (or under other relevant University by-law, policy, procedure) and unless specifically authorized by the Head of Unit in authority over the University Member and the situation giving rise to a Conflict of Interest.
4.4 The best interests of the University shall always prevail when a University Member is in a situation of Conflict of Interest or when the personal interest of a Related Party places a University Member in a situation of Conflict of Interest.
5. SITUATIONS OF CONFLICT OF INTEREST
The Conflict of Interest situations described in this Section are not permitted.
5.1 Hiring, or giving preferential treatment to, a Related Party
a) University Members must ensure that they do not hire, appoint, engage, instruct, supervise, evaluate or otherwise have under their administrative responsibility a Related Party. University Members must not participate in or otherwise authorize or influence such hiring, appointment, engagement, instruction, supervision or evaluation of a Related Party.
b) University Members must not give preferential treatment to a Related Party when performing their University Responsibilities or use their position to help any person or body, enterprise or association in dealings with the University in a situation which gives rise to real or perceived preferential treatment from the perspective of a reasonably well informed and impartial person.
5.2 Multiple/Simultaneous University roles
University Members must devote their time, attention and skill during normal working hours to their primary University Responsibilities. University employees must not simultaneously provide services to the University as a consultant or service provider. Full-time University employees must not simultaneously work in another full-time University position or role. University Members must not offer to another University Member, or accept from another University Member, another University role, employment, appointment, engagement or opportunity with additional responsibilities that could create a Conflict of Interest.
5.3 Engaging in an outside business or undertaking
a) University Members must not become employed or engage in a business or undertaking outside their employment or appointment with the University if it creates a Conflict of Interest or if University premises, equipment, supplies, information, other University property or assets, are used in such employment or engagement.
b) University Members must not have a personal interest in a contract or a proposed contract to be entered into by the University or a University-related body, or obtain a personal advantage or benefit as a result of a decision made by the University or a University-related body.
5.4 Participating in University decision-making where there is personal gain
a) A University Member must not participate in University decision-making with respect to a matter that the University Member is able to influence in the course of their University Responsibilities if as a result of the decision, the interests of the University Member could conflict with the interests of the University, or the University Member could personally benefit from the decision.
5.5 Accepting gifts
a) University Members must not accept a gift (except those mentioned in Section 5.5 b) from the following persons or entities if a reasonable person might conclude that the gift could create a Conflict of Interest :
1) A person, group or entity that has business dealings with the University,
2) A person, group or entity to whom the University Member provides services in the course of their University Responsibilities,
3) A person group or entity that seeks to do business or otherwise engage with the University.
b) The acceptance of minor or customary gifts, gratuities or favours of a trivial or nominal value may be permissible provided that doing so:
1) does not place and does not have the appearance of placing the recipient University Member or anyone else at the University under any obligation;
2) does not give the impression that there is a purpose or attempt to influence University decisions; and
3) that there are no other circumstances that give rise to a Conflict of Interest.
6. DISCLOSURE
6.1 If a University Member is in a Conflict of Interest, the University Member, or any other person with knowledge of the Conflict of Interest, must disclose the nature and extent of a Conflict of Interest to the Head of Unit in authority over that University Member without delay. The University Member that is the subject of the Conflict of Interest must cooperate in the assessment of the situation and in the management or resolution of it.
6.2 Until the Conflict of Interest is disclosed, assessed and managed in accordance with this Policy to the satisfaction of the University person in authority over that University Member, the University Member must continue to fulfill their primary University Responsibilities (unless doing so creates a Conflict of Interest) and must not engage in activities, services or situations giving rise to the Conflict of Interest.
6.3 Where a Conflict of Interest is disclosed or is otherwise revealed, the Head of Unit in authority over the University Member involved in the Conflict of Interest must assess and take appropriate mitigating action to either manage the Conflict of Interest situation in accordance with this Policy or the University Member must take appropriate action to remove the situation giving rise to the Conflict of Interest. The Head of Unit in authority over the University Member involved must document the mechanism or measure(s) that will be utilized to mitigate the Conflict of Interest or the action taken to remove the situation giving rise to the Conflict of Interest. Prior to the Head of Unit in authority over that University Member concluding on their assessment and on mitigation measures or on actions to remove the situation giving rise to the Conflict of Interest, they must consult with Human Resources Service and/or from Procurement Services, as applicable to the situation.
6.4 A Conflict of Interest can be permitted by the Head of Unit in authority over the University Member if it is disclosed in accordance with this Policy and is managed in such a manner that meets all of the following requirements:
a) is compliant with other University by-law, policy, procedure or governing instrument and with applicable law; and
b) protects the integrity, reputation of the University; and
c) is in the best interests of the University; and
d) can withstand public scrutiny.
If at any time any one of the requirements above cease to be met, then the Conflict of Interest is no longer considered to be manager appropriately and is not permitted. The Head of Unit in authority over the University Member shall so inform the University Member and afford the University Member an opportunity to resolve the Conflict of Interest.
6.5 If the Head of Unit in authority over the University Member has reasonable cause to believe that the University Member has failed to disclose a Conflict of Interest or comply with measures to manage it or resolve it, they shall inform the University Member of the basis for such belief and afford the University Member an opportunity to explain the alleged failure to disclose or comply.
7. ENFORCEMENT
7.1 Where a University Member has concealed or has unreasonably failed to disclose a Conflict of Interest or otherwise does not respect this Policy, they may be subject to disciplinary and corrective action, up to and including termination of employment, appointment, contract or of any other engagement with the University.
8. APPROVAL AND AMENDMENTS
8.1 The Secretary-General is responsible for periodic review of this Policy, for interpreting this Policy and for recommending to the Administration Committee any amendments to it.
8.2 Amendments to this Policy require the approval of the Administration Committee
8.3 The Secretary-General may establish, amend or abrogate procedures for purposes of the effective implementation of this Policy, provided that such procedures are consistent with the provisions of this Policy.
8.4 Notwithstanding 8.2 of this Policy, the Secretary-General may amend this Policy without the need to submit such amendment to the Administration Committee for approval if such amendment is required to:
a) update or correct the name or title of a position, unit, law, bylaw, policy, procedure or authority; or
b) correct punctuation, grammar, typographical errors, revisions to format and other technical revisions, where appropriate, if the correction does not change the meaning of a provision, or make such other correction if it is clear both that an error has been made and what the correction should be; or
c) correct the form of expression of a provision in French or in English to be more compatible with its form of expression in the other language; or
d) make consequential amendments to conform with or arising from another University bylaw, resolution, policy or procedure.