Outside Activities
True or False: Sitting on the board of directors for a for-profit entity is okay.
False: No employee may serve as a member of a board of directors, an executive, or as an officer, (whether compensated or uncompensated), of any for-profit legal entity, competitor of MD Anderson, or any other for-profit legal entity reasonably related to an employee’s Institutional Responsibilities.
Can I put my daughter’s Girl Scout cookie order form in the break room?
No. MD Anderson’s Charitable Activities, Charitable Expenditures, and Solicitation Policy prohibits the sale of products to raise funds for organizations or activities not authorized by MD Anderson (e.g., Girl Scout Cookies).
One of our department’s vendors sent gift cards for every workforce member in our office. Are we allowed to accept the gift cards?
No. In general, non-cash gifts valued at less than $50 may be accepted unless the workforce member has any reason to believe that the gift is being offered to influence them or the decisions they make. Cash or cash equivalents (e.g., gift certificates, gift cards, vouchers) should not be accepted from any vendor or third party who is doing or is interested in doing business with MD Anderson.
An employee I supervise wants to attend a three-day conference in Washington, D.C., that includes a day of lobbying. She will go to the U.S. Capitol and speak to legislators about cancer rights. Who should I contact regarding this?
MD Anderson workforce members can engage in political activities on their own time but must contact Government Relations beforehand and cannot use state resources for these activities. Any lobbying must be done on personal time, and related expenses cannot be reimbursed by MD Anderson
A small company specializing in drugs pertaining to breast cancer has offered me an honorarium to participate on their panel discussion at an international conference. My expertise is in another type of cancer. Am I allowed to participate?
No. Institutional Personnel may not solicit, accept, or agree to accept honoraria in consideration for services that they would not have been requested to provide but for their official status or institutional duties.
May I use the copy machine to copy flyers for my child’s birthday party?
No. Copying flyers for your child’s birthday party is not considered an incidental use.
A pharmaceutical company’s representative would like to sponsor a holiday lunch for the department. Is this okay?
No. Meals or other types of food directly funded or provided by medical service representatives (such as pharmaceutical company employees) are prohibited. Food for non-educational events such as faculty meetings must not be accepted under any circumstances. See our Funding for Accredited and Non-Accredited Educational Activities Policy (#ADM1020).
True or False: An FDA inspector has just arrived in my lab. The first thing I need to do is let them in.
False. The first thing you should do is contact Institutional Compliance at 713-745-6636. We’ll verify the person’s identity and work with you to ensure any information we give them is appropriate.
My spouse works for the pharmaceutical company that is the sponsor of the clinical trial I work on. Do I need to disclose their work?
Yes. Disclosure within 30 days is required for any activity of an Affiliated Persons (spouse, dependent, etc) that reasonably appears to create a COI and/or Conflict of Commitment.
I sell cosmetics in my spare time and process order requests using my computer at work. Does this present any problems?
Yes, this activity is problematic. A state employee may not use state resources, which include state time or property, to conduct a personal business. You also may not use state property during your lunch break or after work hours to conduct a personal business. See our Use of State-Owned Property, Equipment, Services, Funds, and Resources Policy (#ADM0340).
To get more patients to come to our department, we would like to raffle an iPad. Is this okay?
No. It’s against federal and state law to offer gifts to a patient in order to get the patient’s business. In addition, there are special rules regarding raffles in the State of Texas. For more information, contact our Legal Services department at 713-745-6633.
I'm a researcher at MD Anderson and I want to collaborate with colleagues at an academic institution in Iran. Who do I need to contact first?
Any work with certain countries such as Syria, Iraq, Iran, North Korea, Russia, Cuba, and others may require an Export Control license from the federal government before exchanging any materials or data. Failure to do so may result in fines or criminal liability. Accordingly, you should contact Institutional Compliance before engaging in any international collaboration for guidance, but this is particularly true for certain Countries of Concern that are subject to more stringent Export Control regulations.
I recently bought stock in a company that is also doing business with MD Anderson. Do I need to do a disclosure?
Yes. Equity interests or other Ownership interests must be disclosed within 30 days of acquiring the interest.
I’m starting a company and want to invite my colleagues to an event that is promoting my products. Can I use my MD Anderson email to send all of them flyers and RSVP?
No, your MD Anderson email is considered a state resource and can only be used for Institutional purposes. Additionally, state resources cannot be used to benefit third parties or individuals.
A vendor wants to take our group out for dinner (outside the institution) to an expensive steakhouse. Am I allowed to go?
No. Within reason, individual meals with Vendors are permissible as long as the Vendor is present as host, and no attempt to influence or appearance of influence exists.
A patient recently gave their care team gift cards valued at $500. The patient will not accept the gift cards back. Who do you call?
Institutional Personnel may either contact the Director of Social Work or contact the Institutional Compliance Office (713-745-6636) for further guidance.