Conflict of Interest

Policy

EXECUTIVE SUMMARY
CONFLICT OF INTEREST POLICY AND PROCEDURES

Introduction:
  • Conflicts of interest exist when an individual’s personal financial interests could improperly influence execution of his/her University responsibilities.
  • Conflicts are not inherently unacceptable, but must be identified and managed to prevent damage to the individual and the institution.
Policy applies to “significant financial or other interests” defined as:
  • Salary or other payments for services if equal to or greater than $10,000/year for the employee and/or his/her family members;
  • equity interests (e.g., stocks, stock options or other ownership interests) equal to or greater than $10,000 and/or 5% of a business entity held by the employee and/or her/his family members;
  • intellectual property rights (e.g., patents, copyrights and royalties from such rights);
  • holding of a position as an officer, director, agent, or employee of a business entity by the employee and her/his family members.
  • Does not include salary from the University, payment for services to public or non-profit entities, income from mutual funds, ownership interests in businesses applying for SBIR/STTR Phase I projects.
Policy requires disclosure of information at the following activities:
  • submission of a new grant/contract/protocol to the Office of Sponsored Projects
  • submission of a protocol to the Institutional Review Board
  • request for signature authority on a University account
  • if a (new) potential for conflict arises after the original submission for any of the above activities
Policy prohibits the following activities:
  • Academic freedom restrictions such as prohibitions on publication by subordinates;
  • Payments, gifts, incentives directly or indirectly to individuals conducting human subjects research, other than through the research account for that project;
  • Solicitation or receipt of gifts in violation of the Utah Public Employees’ Ethics Act.
The information required for disclosure:
  • Purchasing/procurement: Does the discloser have a significant financial or other interest in a business that could benefit from the discloser’s signature authority?
  • Research/sponsored projects:
    1. Description of the project for which the disclosure is being made – PI, title, funder, anticipated funding date, if human subjects are involved.
    2. Whether or not the discloser has a significant financial or other interest in a business sponsoring the research or whose business is substantially related to subject of the research.
    3. If the discloser has such an interest:
      • the nature of the interest,
      • the conflict it creates,
      • how the discloser proposes to manage the conflict.
After a disclosure is submitted to the Conflict of Interest Committee:
  • All disclosures are reviewed by the Committee and staff.
  • A determination is made whether or not a conflict of interest exists.
  • The discloser is notified of the results of the determination.
  • If a conflict exists, the Committee works with discloser to “manage, reduce or eliminate” the conflict.
  • Results of the review are provided to OSP, IRB, Purchasing as necessary.
Acceptable strategies to “manage, reduce or eliminate” conflicts include:
  • Disclosure of the conflict to journals where research results submitted;
  • Disclosure of the conflict to potential human subjects;
  • Changes to informed consent document(s);
  • Decision-making by a non-conflicted member of the research team;
  • Monitoring of aspects of the research by a non-conflicted peer, not a member of the research team.

For the full policy see: University of Utah PPM 2-30