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Conflicts of Interest in Sponsored Programs

Conflicts of interest can arise in sponsored programs when personal financial interests are held by researchers in a company either sponsoring the research or potentially benefiting from the results of the research. They may also occur when the university subcontracts to a company owned by the researcher or a member of his or her family. As stated in the university’s Conflict of Interest Policy pertaining to sponsored projects:

The University and its Employees often benefit from Employees' participation in both public and private outside activities. The University has no interest in unreasonably interfering with Employees' legitimate outside interests. University Employees, in turn, have an obligation to ensure that their outside obligations, financial interests, and activities do not conflict or interfere with their commitment to conduct University research and other sponsored activity without improper influence, and to disclose to the University all actual or potential conflicts of interest.

The areas of potential conflict may be divided into two categories. Conflicts of Interest are situations in which Employees may have the opportunity to influence the University's business decisions in ways that could lead to personal gain or give improper advantage to members of their families or to associates. Conflicts of Commitment are situations in which Employees' external activities interfere or appear to interfere with their paramount obligations to students, colleagues, and the University.

To assist faculty and research staff in identifying potential conflicts and managing those that exist, the university has created a Conflict of Interest Committee. That Committee is composed of the Vice Provost for Research, the University General Counsel, the Director of the Office for Sponsored Programs, and the Director of the Office for Research Integrity and Compliance, and the Director of the Office of Technology Transfer and Licensing.

Conflicts of interest may be serious or relatively benign. Actual conflicts of interest must be disclosed (see Conflict of Interest Disclosure Forms below) so that the committee can evaluate the conflict and, if necessary, develop a plan to manage it. It is important for researchers to anticipate and manage even the potential perception of a conflict of interest, since it could have a negative effect on the public’s view of the researcher’s work. Guidelines on acceptable and unacceptable external affiliations can be found in the Resources section at the bottom of this page. Contact Stephen Erickson, Director, Office of Research Integrity and Compliance if you would like more information, or if you would like to discuss a possible conflict of interest.

Researchers also need to avoid situations that place them in a conflict of commitment. Conflicts of commitment are defined as situations in which faculty members' external activities interfere or appear to interfere with their paramount obligations to their students, colleagues, and the University. The conflicts may occur when a researcher’s time is dedicated too greatly to external affiliations to the detriment of his or her university responsibilities. As is the case with financial conflicts of interest, it is important for researchers to avoid even the perception of a conflict of commitment.

If you would like to discuss the development of an educational session on identifying and preventing conflicts of interest, please contact Stephen Erickson.

Resources:

Boston College

Conflict of Interest Policy Pertaining to Sponsored Projects
Conflict of Interest Disclosure Form
Addendum to Conflict of Interest Policy for PHS Funded Grants (this includes NIH grants)
Conflict of Interest Disclosure Form for PHS Funded Grants

Accepted conflict of interest tutorials for PHS funded grants:
CITI Program Module on Conflict of Interest
NIH Financial Conflict of Interest Module

Guidelines on Conflicts of Interest
Business Ethics Hotline
Conflicts of Interest Not Involving Sponsored Funding

External

National Institutes of Health Financial Conflicts of Interest
National Science Foundation Conflict of Interest Policy
Association of American Universities Report on Conflicts of Interest