Policy
The School of Dentistry is committed to operating in an ethical and legal manner. All School of Dentistry employees are required to adhere to State and Federal laws and rules, University of Washington policies, and the School’s Compliance Program and Code of Conduct. It is School policy that employees avoid or disclose and address interests and activities that might conflict with the proper discharge of the employee’s official duties. This policy provides guidance on reporting potential conflict of interest situations, as it is the responsibility of each faculty and staff member to bring these issues forward.
Gifts
The UW School of Dentistry (UWSOD) benefits from the ongoing generosity and support of its donors, be they private individuals or commercial entities. School Administrators, Program Directors, or their designees will notify Advancement of all gifts and donations to the School. Gift and donation proposals must also be reported to Advancement for review prior to acceptance. Advancement will track all gifts and in-kind donations. Donors will receive formal acknowledgement from the UWSOD.
University policies and guidelines, and the Washington State Ethics Act put limits on gifts that *individual* state employees may accept. Whereas the occasional grateful patient may offer home-baked goods, flowers, chocolate, or other modest items (all of which are acceptable and can be shared with co-workers), employees are encouraged to maintain a professional relationship with patients and commercial entities. Employees should avoid personally accepting gifts from commercial entities to maintain impartiality.
There are some Items that all state employees may receive:
- Items from family/friends when clear beyond reasonable doubt there is not any intent to gain influence in the School or individual’s decision-making
- Items related to an outside business of the recipient that are customary and not related to recipient’s performance of official state duties
- Items exchanged among employees or a social event hosted by a state employee for coworkers
- Group discounts
- Awards, prizes or scholarships provided in recognition of academic or scientific achievement
- Food and beverages consumed at hosted receptions (not sit-down meals) where attendance is related to employee’s official state duties
- Unsolicited promotional items of nominal value such as pens
- Unsolicited tokens or awards such as trophies and plaques
- Informational material, publications, or subscriptions related to official duties
- Admission to, and the cost of food and beverages consumed at, events sponsored by or in conjunction with a civic, charitable, governmental, or community organization
- Free and local education related to employee’s work/profession
Limitations on state employees who have influence over purchasing/contracting
State employees participating in state business through approval, disapproval, decision, recommendation, or rendering of advice may only accept the items which all state employees may receive (see section above).
Items state employees without influence over purchasing/contracting may additionally receive:
- Gifts up to $50 per year per source (cumulative)
- Payment of enrollment, course fees, and travel expenses of attending seminars and educational programs sponsored by a bona fide governmental or nonprofit professional, educational, trade, or charitable association or institution
- Payments by a governmental or nongovernmental entity of reasonable expenses incurred in connection with a speech, presentation, appearance, or trade mission made in an official capacity. Official capacity means within scope of duties and on work time
- Unsolicited flowers
- Food and beverage on infrequent occasions in the ordinary course of meals where attendance by employee is related to the performance of official duties
This is not an exhaustive list of examples; contact the Director of Compliance for additional information.
Vendor Sponsored Lunch & Learn Events – Contact your Department/Clinic Administrator prior to planning or attending vendor sponsored “lunch and learn” educational activities to avoid potential violations of the State Ethics Act, anti-kickback and other laws.
Personal Use of State Resources – All employees are responsible for proper stewardship of University resources, including but not limited to, people, money, property, time, equipment, vehicles, computer software, trademarks and intellectual property. Limited personal use of State resources may be permitted under certain conditions. See the University Policy on personal use of state resources. Contact your Department/Clinic Administrator with questions or concerns.
Lobbying – No state resources, under any circumstances, may be used for lobbying, assisting an election campaign, or promoting/opposing an initiative. This prohibition includes the use of employee work time to engage in these activities. Careful review of potential violations is required. Contact your Department/Clinic Administrator with questions or concerns. See additional information at UW Policy (PDF).
Independent Organizations – Employees must avoid conducting business on behalf of other organizations including student-sponsored associations. Direct all questions and report all concerns to the Manager of Student Life & Admissions at 206-685-2372.
The Director of Compliance is available for questions at 206-543-5331 . Confidential concerns can be reported via the Compliance Hotline at 206-685-5254 or dcomply@uw.edu.
Outside employment for compensation
Outside employment activities for faculty are reported on the Request for Approval of Outside Professional Work for Compensation form, UW form 1460. Professional and Classified staff must use the 1555 form (PDF) to request approval for outside work.
Activities that fall in the outside work category should not be performed with state resources or on state time. A conflict of interest review is an important part of the review process.