Conflict
of Financial Interest Policy for Grant-Funded Research or Other Academic
Projects
[Faculty
Handbook Category #3]
1. Policy Statement. In accordance with federal regulations and
in keeping with St. Olaf’s commitment to the
highest standards of integrity and ethics in research,
2. Definitions.
a. For purposes of this Policy, the term
“Researcher” shall mean the principal investigator, the co-principal
investigator and any other person who is responsible for the design, conduct,
or reporting of research or other educational activities funded or proposed for
funding by the National Science Foundation (‘NSF”), the Public Health Service
(“PHS”), or any other external public or private entity. Any individual responsible for a task that
could have a significant effect on the research design, conduct or reporting is
considered to be a Researcher, even if the individual does not have sole or
primary responsibility for the task or the research.
b. For purposes of this Policy, the term
“Significant Financial Interest” means anything of monetary value, including
salary or other payment for services, equity interests, and intellectual
property rights. While this term is
intended to be read broadly, the following items of monetary value will not be
considered a Significant Financial Interest: (i)
salary or other remuneration from St. Olaf College, (ii) income from seminars, lectures, or
teaching engagements sponsored by public
or non-profit entities; (iii) income
from service on advisory committees or review panels for public or non-profit entities;
(iv) an equity interest that, when aggregated for the Researcher and the
Researcher’s spouse and dependent children, does not represent more than a 5%
ownership interest in any single entity and
does not exceed $10,000 in value as determined through reference to public
prices or other measures of fair market value; and (v) salary, royalties or
other payments, from an entity other than St. Olaf College, that when
aggregated for the Researcher and the Researcher’s spouse and dependent
children, are not expected to exceed $10,000 during the twelve-month period.
2. Procedure. Each Researcher must complete and sign a
Disclosure of Financial Interest Form, at the time of application for an award
and annually for the duration of the award.
The form requires researchers to disclose Significant Financial Interests:
(i) that would reasonably appear to be affected by
research or educational activities funded or proposed for funding by an
external source, such as the NSF or PHS; or (ii) in entities whose financial
interests would reasonably appear to be affected by such activities. A copy of this form is available from the
Office of Government and Foundation Relations.
Additional disclosures may be required based on the specific grant or
other funding requirements.
The Assistant
Provost has been designated to review disclosures of Significant Financial
Interests, to determine whether an actual, potential or perceived conflict of
interest exists, and to determine what conditions or restrictions, if any,
should be imposed by the College to manage, reduce or eliminate such actual,
potential, or perceived conflict of interest. A conflict of interest exists
when the Assistant Provost reasonably
determines that a Significant Financial Interest could directly and
significantly affect the design, conduct, or reporting of research or
educational activities funded by the grant.
Examples
of conditions or restrictions that might be imposed to manage, reduce or
eliminate conflicts of interest include, but are not limited to:
(a) public
disclosure of Significant Financial Interests;
(b) monitoring of
research by independent reviewers;
(c) modification of
the research plan;
(d)
disqualification
from participation in the portion of the funded research that would be affected
by significant financial interests;
(e) divestiture of
Significant Financial Interests; or
(f)
severance
of relationships that create conflicts.
If the Assistant Provost determines that
imposing conditions or restrictions would be either ineffective or inequitable,
and that the potential negative impacts that may arise from a Significant Financial
Interest are outweighed by interests of scientific progress, technology
transfer, or the public health and welfare, then the College may allow the
research to go forward without imposing such conditions or restrictions.
3. Enforcement and Violations. A
Researcher who fails to disclose a Significant Financial Interest or to comply
with the conditions or restrictions imposed by the College is subject to
discipline up to and including termination or dismissal.
The Assistant Provost is responsible for
keeping the NSF’s Office of the General Counsel, the PHS, and other relevant
public and private entities appropriately informed if the College finds that it
is unable to satisfactorily manage a conflict of interest.
The College shall
maintain records of all financial disclosures and of all actions taken to
resolve conflicts of interest for at least three years beyond the termination
or completion of the grant to which they relate, or until the resolution of any
NSF or other administrative or legal action involving those records, whichever
is longer. The College shall strive to
maintain the confidentiality of all financial disclosures; however, such
disclosures may be subject to government audit, court subpoena, or other
legally required disclosure.
Collaborators from
other institutions must either comply with this policy or provide a
certification that their institutions are in compliance with federal
regulations regarding research conflicts of interest and that they have
complied with their institutional policies with regard to disclosures of
significant financial interests.