Conflict of Interest
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.
It is the purpose of the Conflicts of Interest in Research Policy and Procedures to set forth the principles for identifying the potential for conflicts and the procedures for reviewing and addressing actual and potential conflicts to assure that they do not improperly affect University research and other sponsored activities. In addition, the intent of this policy is to assist Investigators to more effectively manage real or potential conflicts of interest and commitment. By reporting and managing conflicts from the start, the University and the Investigator can work together to prevent outcomes that may be harmful to either the Investigator or the University at large.
Disclosures of conflicts of interest should be made on grant proposals, IRB protocol proposals, and agreements concerning intellectual property. To assist faculty and research staff in identifying potential conflicts and managing those that exist, the university has created a Conflict of Interest Committee to evaluate disclosures of conflicts of interest 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.
If conflict of interest training is needed for PHS funded grants, this can be completed through CITI.
Conflicts of commitment are addressed in the Faculty Handbook.
If you have any concerns or questions and would like to discuss a matter further, please contact Bill Nunez.
Policy and Forms
National Institutes of Health Financial Conflicts of Interest
National Science Foundation Conflict of Interest Policy
Guidelines on Conflicts of Interest
a. Acceptance of royalties for published works and patents, or of honoraria for commissioned papers and lectures.
b. Service as a consultant to outside organizations, provided that the time commitment does not exceed the then existing University policy, and that the arrangement in no way alters the Employee’s commitments incurred in the University's execution of a sponsored agreement on the Employee’s behalf.
c. Service on boards and committees of organizations, public or private, that does not distract unduly from the Employee’s obligations to the University or that does not interfere or appear to interfere with an Employee’s ability to conduct work under sponsored agreements objectively.
a. Relationships that might enable an Employee to influence the University's dealings with an outside organization in ways leading to personal gain or improper advantage for the Employee, or his or her associates or family members. For example an Employee or immediate family member could have a financial interest in an organization with which the University does business and could be in a position to influence relevant business decisions. Ordinarily, making full disclosure of such relationships and making appropriate arrangements to mitigate potential conflicts would resolve such problems.
b. Situations in which the time or creative energy a Employee may devote to external activities appear substantial enough so as to compromise the amount or quality of his or her participation in the instructional, scholarly, and/or administrative work of the University.
c. Situations in which a faculty member directs students into a research area from which the faculty member may realize a financial gain. In such situations, the ability of a faculty member to render objective, independent judgment about the students' scholarly best interests may be diminished.
a. Situations in which an Employee assumes executive responsibilities for an outside organization that might seriously divert his or her attention from University duties. Employees should consult with the appropriate department chair or dean before accepting any outside management position.
b. Use for personal profit of unpublished information emanating from sponsored agreements or confidential University sources, or assisting an outside organization by giving it exclusive access to such information; or consulting with outside organizations that impose obligations upon the Employee or the University that conflict with the Employee’s or University's Intellectual Property Policy or with the University's obligations under Sponsored Projects.
c. Circumstances in which a substantial body of research that could and ordinarily would be carried on within the University is conducted elsewhere to the detriment of the University and its legitimate interests.
d. Any activity that an Employee may wish to undertake on an individual basis that (a) involves or appears to involve the University significantly through the use of its resources, facilities, or the participation of academic colleagues, students, and/or staff, (b) involves the use of the University's name or implied endorsement, or (c) violates any of the principles set forth in the University Research and Projects Policy (for example, giving the outside organization the right to censor or prohibit publication rights for research any part of which is performed under University auspices).