SLAC Conflict of Interest Requirements and Obtaining Approval for Concurrent Outside Employment or Professional Engagement

I. Policy on Disclosing and Avoiding Conflicts of Interest

Conflicts of interest occur when employees’ outside activities could influence their professional conduct, including allocation of time and energy, due to considerations of personal gain (financial or otherwise). At a minimum, Stanford and DOE requires SLAC employees to disclose to, and obtain approval from, the SLAC Director before engaging in any outside employment or engagement in a professional capacity in addition to their employment at SLAC.

University and DOE policies on conflict of interest require avoidance of the following situations:

• Use of privileged or proprietary information for personal gain or other unauthorized purposes
• Use of SLAC or University-supported work, products, results, materials, property records, or information without authorization
• Defining contract terms or specifications, obtaining procurement sensitive information, or serving as an evaluator or initiator relating to a requisition in which the employee has a personal interest
• Acceptance (or giving) of gratuities or special favors from (or to) the DOE or private organizations or individuals with which SLAC or the University conducts business
• Direct participation in career-related decisions of a relative, spouse, or member of one’s household who is also a SLAC employee
• Current, future, or expected participation in a Foreign Government Talent Recruitment Program of a Country of Risk, or a Foreign Government or Entity Sponsored or Affiliated Activity of a Country of Risk
• Non-compliance with or performance of work outside the parameters of other sponsor disclosure requirements, if applicable to the employee's work

II. Concurrent Outside Employment or Professional Engagement

A. Policy on Concurrent Outside Employment or Professional Engagement

Concurrent outside employment or engagement in a professional capacity can raise conflict of interest and conflict of commitment concerns. SLAC employees who wish to engage in concurrent outside employment or professional engagement must demonstrate that this poses no conflict of interest or commitment. There are a number of criteria governing concurrent employment and professional engagements. In addition to the conflicts rules above, employees may not:

• Sacrifice, hamper, or impede their normal duties at SLAC
• Perform duties at SLAC that involves them in any way with an outside employer
• Perform “outside” work on SLAC time or perform such work using SLAC, Stanford or government property
• Be a consultant to a company on preparation of a bid, offer, or unsolicited proposal to SLAC
• Use their position at SLAC to provide an unfair competitive advantage to the potential outside employers
• Participate in Foreign Talent Recruitment Program, or in a Foreign Government or Entity Sponsored or Affiliated Activity, as described above in Section I
• Appear to subject DOE or SLAC to public criticism or embarrassment

B. Required Form for Concurrent Outside Employment or Professional Engagement

Approval of concurrent outside employment or engagement in a professional capacity must be obtained before the activity starts. It is important to note that activities subject to approval include:

• Accepting employment, consulting, compensation (whether monetary or in-kind), or a leadership position with any outside entity; and
• Accepting or acquiring a significant ownership stake in an outside entity with which SLAC may do business or currently does business with (defined as greater than or equal to a 5% share)

Only the SLAC Director can approve requests for outside employment or professional engagement. If you wish to request authorization for such activities, you must do the following: 1) complete the form "Obtaining Approval for Concurrent Outside Employment or Professional Engagement" below; and 2) obtain concurrence signatures from line management and submit to Legal at conflictsofinterest@slac.stanford.edu for approval.

III. Guidelines and Form

• SLAC Legal Video Training on Conflicts of Interest (SLAC login required)
• Obtaining Approval for Concurrent Outside Employment and Professional Engagement Form (SLAC login required)
• Director's Memorandum Concerning Conflicts of Interest and Commitment (SLAC login requried)
• Policy Memorandum: Conflict of Commitment and Interest (SLAC login required)
• Guidelines for Avoiding Personal Conflicts of Interest (SLAC login required) 
• DOE Definition of "Foreign Country of Risk" (SLAC login required)
• Administrative Guide Memo 1.5.2, "Staff Policy on Conflict of Commitment and Interest"
• Administrative Guide Memo 2.1.2, Part 2c, "Employment of Related Persons"
• Research Policy Handbook Section 4.1, “Faculty Policy on Conflict of Commitment and Interest”
• Research Policy Handbook Section 4.3, “Consulting and Other Outside Professional Activities. . .”
• Attachment 1 – DOE Order 486.1A (SLAC login required)

SLAC faculty should also consult the Stanford University Faculty Handbook, Chapter 2, Section 2.7.8 Close Relatives of the Faculty.