1. Responsible Conduct in Research Conflict of Interest and Commitment

2. DEFINITIONS Conflict of Interest - A "conflict of interest" in a university/research setting generally refers to situations in which the external interests of the institution’s employee have the potential to influence his or her decisions in his or her professional role. The influence is generally in ways that could lead to personal gain (financial or non- financial) for the individual or immediate family members. Conflict of Commitment - In contrast to conflicts of interest which typically are financial, conflicts of commitment deal with situations in which there are “divided loyalties.” The conflict arises when a decision does not necessarily provide financial benefit for the individual or his/her family – but in which other commitments (typically relationships) interfere with objective decision making and my cause detriment to the Institution. Conflict of Interest & Commitment

3. In various research settings, individuals often face competing obligations and conflicting interests. These may include, but are not limited to: Competing professional obligations, such as time spent teaching versus time spent conducting research or time spent consulting versus time spent conducting research Conflicting personal interests and professional obligations, such as the pressure to publish versus the obligation to report research data honestly and accurately Conflicts of interest can be categorized as to whether they are real, potential, or perceived. Most conflicts of interest are real, in that the conflict has the capacity to bias a researcher’s professional judgment regardless of the researcher’s actions. Regardless of whether a COI is real or perceived, it must be addressed and mitigated if necessary. Disclosure of a conflict can be a key factor in protecting a researcher’s reputation and career from potentially harmful allegations of unethical behavior. Although disclosure of a conflict of interest does not resolve the ethical issues presented by the conflict, it is an important first step. Conflict of Interest and Commitment

4. The following list provides examples of activities or actions that have the potential of creating a conflict of interest. Consulting activities. The purchase of goods or services from businesses in which an employee or his/her family has a financial interest or, as the result of such purchase, may directly benefit. Receipt of gifts, gratuities, loans, or special favors from research sponsors or vendors. Holding of an equity, royalty, or debt instrument by the employee or the employee’s family in an entity that provides financial support to the employee’s institute/organization, including research or other support or services, if this support will benefit the employee or persons who are supervised, either directly or indirectly, by the employee. Receipt, directly to the employee from non-institutional/organizational sources of cash, services, or equipment provided in support of the employee’s institutional/organizational activities. Use of information received as anemployee (that is not otherwise publicly available) for personal purposes and financial gain. IDENTIFICATION OF CONFLICTS OF INTEREST

5. Situation: A research institute employee serves as PI or Co-PI on a grant that includes a subcontract to a member of the employee's immediate family. Why could this be perceived to be a conflict of interest? Subcontracting to a member of one's family gives the perception of use of Federal or state resources for personal gain. Note that when funds are given to the university/research institution from any source, they become university/institute funds. What should the employee do? The employee should disclose the conflict. The situation will be reviewed by the Compliance Office and the President to determine if there is a way to reduce or eliminate the conflict. If needed, a management plan will be established to prevent the institute employee from using, or appearing to use, his/her position to benefit his/herself or the family member. This is generally done by transferring the responsibility for the grant to a third party. Courtesy Iowa State University Conflicts of Interest in Sponsored Funding: Example #1

6. Situation: An employee gets a grant from an engineering company to conduct research on the efficiency of energy conservation in various engine designs, one of which is sold by the engineering company. The employee's spouse owns more than 5 percent of the company stock. Why could this be perceived to be a conflict of interest? The employee's spouse, and therefore the employee, stands to gain financially depending on the outcome of the research, which raises questions about the integrity of the research. What should the employee do? To protect research integrity, institute policy prohibits investigators from receiving grants from entities in which they or their family members have a management role or a significant financial interest. Therefore, the employee should disclose the situation. A management plan will be needed and it will likely either: 1) transfer the grant to a third party to provide oversight, or 2) establish an oversight committee to monitor the integrity of the research. Conflicts of Interest in Sponsored Funding: Example #2

7. COI Mitigation A plan will be developed and recorded to mitigate any identified Conflict of Interest or Commitment. Possible options include, but are not limited to: Public disclosure of the conflict of interest, Reformulation of the research work-plan, Close monitoring of the research project by an independent source, Divestiture of relevant personal interests, Termination or reduction of involvement in the relevant research project, Severance of outside relationships that pose conflicts, or Transfer decision-making to another staff member when a conflict exists. Sometimes the mitigation step(s) are difficult. However, not handling a COI in an upfront and transparent manner can damage reputations of individuals and institutes.

8. Resources Resources on conflict of interest are available from the Office of Research Integrity: http://ori.dhhs.gov/conflicts-interest-and-commitment Conflict of Interest Toolkit for Investigators: http://www.faseb.org/ConflictofInterest University of New Hampshire: http://ori.dhhs.gov/education/products/unh_round1/www.unh.edu/rcr/Conflict- Title.htm http://ori.dhhs.gov/education/products/unh_round1/www.unh.edu/rcr/Conflict- Title.htm Cary Institute of Ecosystem Studies Policy on Conflict of Interest and Commitment: http://www.caryintranet.org/sites/ConflictofInterest

9. I certify that I have completed the RCR Training Module on Research Conflict of Interest and Commitment Date Print Name Signature Certificate of Completion Please print out sign and return to Grants and Compliance Office Click to Print