Faculty Handbook: Conflict of Interest in Research

Policy Statement

Marywood University extends the applicability of the following regulations to all externally funded projects regardless of funding source:  Title 42 of the Code of Federal Regulations, Part 50, Subpart F and the National Science Foundation Grant Policy Manual 510, as amended by 60 FR 35820.

Disclosure Required

Each person participating in a sponsored project covered by this policy must disclose whether or not he or she has external affiliations that may constitute a conflict.  A conflict of interest may occur when an employee, officer, or agent who has an affiliation with the external organization meets any one of the following criteria:

• The employee, officer, or agent is an officer, director, partner, trustee, employee, advisory board member, or agent of an external organization or corporation either funding a sponsored project or providing goods and services under a sponsored project on which the employee, officer, or agent is participating in any capacity.

• The employee, officer, or agent is the actual or beneficial owner of more than five percent (5%) of the voting stock or controlling interest of such organization or corporation or voting stock of such organization or corporation that exceeds $10,000 in value as determined by reference to public prices or other reasonable measures of value.

• The employee, officer, or agent has dealings with such organization or corporation from which he or she expects to receive salary, royalties or other payments of more than $10,000 during the next twelve months.

• The employee, officer, or agent has immediate family (spouse, parents, parents in-law, siblings, children, or other relatives living at the same address as the faculty/staff member), or the employee, officer, or agent together with all members of his or her immediate family meet any of the criteria stated above.

 
A disclosure must be completed

• either prior to the University's submission of a proposal for funding or prior to the acceptance of the sponsored project

• or during any sponsored project, whenever the faculty or staff member has a new external affiliation that may constitute a conflict of interest by falling within the criteria stated above.

The disclosure form is initiated by the Office of Research and Community Collaboration (ORCC). Positive disclosures will be reviewed by the Assistant Vice President for Research in keeping with the current University policies and federal regulations relating to conflict of interest in research and a recommendation made regarding the potential conflict.

Note:   Certain sponsors, particularly federal agencies, may have requirements that differ from this policy with regard to the timing and frequency of faculty disclosures and other conflict of interest considerations as well. In the case of such discrepancies, the sponsors' requirements will generally prevail.

Violations

 Violations of this policy, such as willful concealment of financial interests, may result in sanctions being imposed upon the violating individual. The Assistant Vice President for Research will review allegations of violations and will make recommendations regarding the imposition of sanctions to the Provost and Vice President for Academic Affairs.

Records and Confidentiality

 The ORCC shall maintain the records pertaining to each disclosure in strict confidence. Access to such records will be limited to the faculty or staff member, the Provost and Vice President for Academic Affairs, the Assistant Vice President for Research, the Director of Sponsored Projects, and other University administrators as required by their institutional responsibilities.

Definitions

Conflicts of Interest are defined as situations in which employees, officers, and/or agents of the University 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.

Procedures

See ORCC Conflict of Interest Policy link for forms and procedures www.marywood.edu/orcc