Post by Admin on Apr 27, 2015 15:40:01 GMT
The University will exercise oversight and care in eliminating or managing Financial Conflicts of Interest that do or may arise because of an Employee's or an Investigator's Financial Interest in University activities or research activities. The University will not accept or enter into agreements, contracts, gifts or purchases that give rise to a Financial Conflict of Interest. The University will comply with all reporting responsibilities imposed by state or federal laws or regulations with respect to Financial Interests that have been disclosed while protecting the personal privacy of Employees when possible, except where disclosure is required by applicable law or this policy. The University will comply with all federal and state statutes and regulations requiring reporting of or public access to disclosed individual Financial Interests (including Significant Financial Interests) and Financial Conflicts of Interest; the University will maintain the specific fiscal details of disclosed Financial Interests (including Significant Financial Interests) by applicable laws or regulations.
The University will comply with all reporting responsibilities imposed by state or federal laws or regulations with respect to Financial Interests that have been disclosed while protecting the personal privacy of Employees when possible, except where disclosure is required by applicable law or this policy. The University will comply with all federal and state statutes and regulations requiring reporting of or public access to disclosed individual Financial Interests (including Significant Financial Interests) and Financial Conflicts of Interest; however, the University will maintain the specific fiscal details of disclosed Financial Interests (including Significant Financial Interests) and Financial Conflicts of Interest as confidential information to the extent allowed by applicable laws or regulations.
As part of fulfilling his or her responsibilities, and to assist the University in avoiding or managing Financial Conflicts of Interest, each Employee and Investigator must disclose any known Financial Interests that he, she or a Dependent has in any of the following:
1. Any University purchase or procurement of goods or services (whether or not pursuant to a formal contract) or in any investment or loan made by the University.
2. Proposals that are submitted to external sponsors for funding, or, in the case of proposals to PHS agencies, in his or her Institutional Responsibilities.
3. Protocols for research that are submitted for review and approval by a Regulatory Committee (or to a subcommittee).
4. Any agreement relating to University technology or other intellectual property that is or will be subject to negotiations between OTC and any third person or entity.
5. A donor that contributes a monetary gift or gift-in-kind designated to be in support of the Employee’s scholarly activities.
6. For an Employee who is a member of a Regulatory Committee, any Financial Interest that he or she has in any research protocol submitted to that Regulatory Committee (with the Employee also recusing himself or herself from the review process regarding such protocol).
7. For an Employee who is an Investigator, any Significant Financial Interest that he or she has not already disclosed as a Financial Interest.
Such disclosures must be made annually and within 30 days of discovering or acquiring a new Financial Interest.
The University encourages faculty authorship of instructional materials and does not discourage the use of such materials in courses in a faculty member's department. In order to prevent Financial Conflicts of Interest or the appearance of such in selecting instructional materials, every academic department or school must have a policy appropriate to its circumstances that ensures instructional materials are selected for their academic merit.
An Employee or Investigator who fails to make disclosures required by this policy, or who otherwise violates any of the provisions in this policy, may be subject to appropriate sanctions, including but not limited to, discipline for misconduct and/or insubordination under University policies, practices and procedures, up to and including dismissal.
REASON FOR THIS POLICY
This policy confirms the University's commitment to the basic values of openness, academic and scholarly integrity, and integrity of business policy and procedure, independence, and safe and ethical research, as well as to its tradition and expectation that Employees will conduct their relationships with the University with candor and integrity. To ensure the integrity of all institutional activities, including review and conduct of research involving human and vertebrate animal subjects, and the associated fiscal, contractual and procurement transactions, regardless of the source of support, Purdue has elected to apply the same Individual Financial Conflicts of Interest policy to all University activities.
:::::::Defining Terms:::::::
Financial Conflicts of Interest:
Situations where an Employee's Financial Interest (including an Investigator's Significant Financial Interest, where applicable) compromises, or could appear to compromise, his or her judgment or ability to carry out the Institutional Responsibilities associated with his or her appointment or employment. A Financial Conflict of Interest may take many forms, but in general arises when an Employee in a relationship with an outside person or organization is in a position to influence the University's business, research or decisions in ways that could lead directly or indirectly to financial gain for the Employee or the Employee's Dependents or could give an improper advantage to others to the detriment of the University.
When applied to an Investigator, Financial Conflicts of Interest occur in situations in which such Investigator's Financial Interest (including Significant Financial Interest) compromises, or could appear to compromise, his or her professional judgment regarding the design, conduct or reporting of research or if such Financial Interest (including Significant Financial Interest) could directly and significantly affect the design, conduct or reporting of research. The bias such conflicts may conceivably impart not only affects collection, analysis and interpretation of data, but also the hiring of staff, procurement of materials, sharing of results, choice of protocol, involvement of human participants and the use of statistical methods.
Financial Conflicts of Interest also include the use of University facilities, personnel, equipment, IT Resources, confidential information or other resources for purposes that could lead directly or indirectly to financial gain for the Employee and/or his or her Dependents.
Financial Interest:
Any interest that will, could or is intended to lead to a profit or an ascertainable increase in the income or net worth of an Employee, Investigator and/or a Dependent. Such a profit or increase in income or net worth could be realized through the receipt of anything of monetary or potential monetary value, including, but not limited to, payments of any kind (e.g., salary, consulting fees, honoraria, gifts, dividends, distributions, rent, paid authorship, etc.), Equity Interests, an increase in the value of real estate or Equity Interests, or Intellectual Property Rights.
Intellectual Property Rights:
Any interest in intellectual property, including, but not limited to, patents, copyrights, licenses, royalties from such rights, agreements to share royalties and similar interests.
Investigator:
A project director, a principal investigator of a research project and any other person, regardless of title or position, who is responsible for the design, conduct or reporting of research or project results at or involving the University, including Employees, subgrantees, contractors, subcontractors, collaborators and consultants. In general, any individual specifically named in a proposal and any individual identified in a report to the project sponsor or scholarly publication who is responsible for the design, conduct or reporting of research or project results is an Investigator for the purposes of this policy.
Significant Financial Interest
A Financial Interest held by an Investigator and/or an Investigator's Dependent that reasonably appears to be related to the Investigator's Institutional Responsibilities and that consists of one or more of the following:
Remuneration
(including salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, and/or an Equity Interest held in such publicly traded company, if the aggregate value of such remuneration, plus the value of the Equity Interest as of the date of disclosure, exceeds $5,000.
Remuneration (including, but not limited to, salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a non-publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, if the remuneration exceeds $5,000.
More than five percent Equity Interest or ownership in a publicly traded company or business.
Any Equity Interest in a non-publicly traded company or business, regardless of value.
Any Intellectual Property Rights, regardless of value, upon receipt of income related to such rights and interests.
When applied to sponsored project applications (proposals) submitted to and/or awards received from PHS agencies, any reimbursed or sponsored travel (i.e., travel that is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), provided that the travel is not reimbursed or sponsored by a federal, state or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Significant Financial Interest does not include:
An Employee's salary, royalties or other remuneration received from the University and/or the Purdue Research Foundation, or, in the case of Investigators who are not Purdue Employees, salary, royalties or other remuneration from their primary employer.
Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency or an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Income from service on advisory committees or review panels for a federal, state or local government agency or institution of higher education as defined at 20 U.S.C. 1001(a), academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.
Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
For Investigators who are not University Employees, any ownership interest in their primary employer held by the Investigator.
The University will comply with all reporting responsibilities imposed by state or federal laws or regulations with respect to Financial Interests that have been disclosed while protecting the personal privacy of Employees when possible, except where disclosure is required by applicable law or this policy. The University will comply with all federal and state statutes and regulations requiring reporting of or public access to disclosed individual Financial Interests (including Significant Financial Interests) and Financial Conflicts of Interest; however, the University will maintain the specific fiscal details of disclosed Financial Interests (including Significant Financial Interests) and Financial Conflicts of Interest as confidential information to the extent allowed by applicable laws or regulations.
As part of fulfilling his or her responsibilities, and to assist the University in avoiding or managing Financial Conflicts of Interest, each Employee and Investigator must disclose any known Financial Interests that he, she or a Dependent has in any of the following:
1. Any University purchase or procurement of goods or services (whether or not pursuant to a formal contract) or in any investment or loan made by the University.
2. Proposals that are submitted to external sponsors for funding, or, in the case of proposals to PHS agencies, in his or her Institutional Responsibilities.
3. Protocols for research that are submitted for review and approval by a Regulatory Committee (or to a subcommittee).
4. Any agreement relating to University technology or other intellectual property that is or will be subject to negotiations between OTC and any third person or entity.
5. A donor that contributes a monetary gift or gift-in-kind designated to be in support of the Employee’s scholarly activities.
6. For an Employee who is a member of a Regulatory Committee, any Financial Interest that he or she has in any research protocol submitted to that Regulatory Committee (with the Employee also recusing himself or herself from the review process regarding such protocol).
7. For an Employee who is an Investigator, any Significant Financial Interest that he or she has not already disclosed as a Financial Interest.
Such disclosures must be made annually and within 30 days of discovering or acquiring a new Financial Interest.
The University encourages faculty authorship of instructional materials and does not discourage the use of such materials in courses in a faculty member's department. In order to prevent Financial Conflicts of Interest or the appearance of such in selecting instructional materials, every academic department or school must have a policy appropriate to its circumstances that ensures instructional materials are selected for their academic merit.
An Employee or Investigator who fails to make disclosures required by this policy, or who otherwise violates any of the provisions in this policy, may be subject to appropriate sanctions, including but not limited to, discipline for misconduct and/or insubordination under University policies, practices and procedures, up to and including dismissal.
REASON FOR THIS POLICY
This policy confirms the University's commitment to the basic values of openness, academic and scholarly integrity, and integrity of business policy and procedure, independence, and safe and ethical research, as well as to its tradition and expectation that Employees will conduct their relationships with the University with candor and integrity. To ensure the integrity of all institutional activities, including review and conduct of research involving human and vertebrate animal subjects, and the associated fiscal, contractual and procurement transactions, regardless of the source of support, Purdue has elected to apply the same Individual Financial Conflicts of Interest policy to all University activities.
:::::::Defining Terms:::::::
Financial Conflicts of Interest:
Situations where an Employee's Financial Interest (including an Investigator's Significant Financial Interest, where applicable) compromises, or could appear to compromise, his or her judgment or ability to carry out the Institutional Responsibilities associated with his or her appointment or employment. A Financial Conflict of Interest may take many forms, but in general arises when an Employee in a relationship with an outside person or organization is in a position to influence the University's business, research or decisions in ways that could lead directly or indirectly to financial gain for the Employee or the Employee's Dependents or could give an improper advantage to others to the detriment of the University.
When applied to an Investigator, Financial Conflicts of Interest occur in situations in which such Investigator's Financial Interest (including Significant Financial Interest) compromises, or could appear to compromise, his or her professional judgment regarding the design, conduct or reporting of research or if such Financial Interest (including Significant Financial Interest) could directly and significantly affect the design, conduct or reporting of research. The bias such conflicts may conceivably impart not only affects collection, analysis and interpretation of data, but also the hiring of staff, procurement of materials, sharing of results, choice of protocol, involvement of human participants and the use of statistical methods.
Financial Conflicts of Interest also include the use of University facilities, personnel, equipment, IT Resources, confidential information or other resources for purposes that could lead directly or indirectly to financial gain for the Employee and/or his or her Dependents.
Financial Interest:
Any interest that will, could or is intended to lead to a profit or an ascertainable increase in the income or net worth of an Employee, Investigator and/or a Dependent. Such a profit or increase in income or net worth could be realized through the receipt of anything of monetary or potential monetary value, including, but not limited to, payments of any kind (e.g., salary, consulting fees, honoraria, gifts, dividends, distributions, rent, paid authorship, etc.), Equity Interests, an increase in the value of real estate or Equity Interests, or Intellectual Property Rights.
Intellectual Property Rights:
Any interest in intellectual property, including, but not limited to, patents, copyrights, licenses, royalties from such rights, agreements to share royalties and similar interests.
Investigator:
A project director, a principal investigator of a research project and any other person, regardless of title or position, who is responsible for the design, conduct or reporting of research or project results at or involving the University, including Employees, subgrantees, contractors, subcontractors, collaborators and consultants. In general, any individual specifically named in a proposal and any individual identified in a report to the project sponsor or scholarly publication who is responsible for the design, conduct or reporting of research or project results is an Investigator for the purposes of this policy.
Significant Financial Interest
A Financial Interest held by an Investigator and/or an Investigator's Dependent that reasonably appears to be related to the Investigator's Institutional Responsibilities and that consists of one or more of the following:
Remuneration
(including salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, and/or an Equity Interest held in such publicly traded company, if the aggregate value of such remuneration, plus the value of the Equity Interest as of the date of disclosure, exceeds $5,000.
Remuneration (including, but not limited to, salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a non-publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, if the remuneration exceeds $5,000.
More than five percent Equity Interest or ownership in a publicly traded company or business.
Any Equity Interest in a non-publicly traded company or business, regardless of value.
Any Intellectual Property Rights, regardless of value, upon receipt of income related to such rights and interests.
When applied to sponsored project applications (proposals) submitted to and/or awards received from PHS agencies, any reimbursed or sponsored travel (i.e., travel that is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), provided that the travel is not reimbursed or sponsored by a federal, state or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Significant Financial Interest does not include:
An Employee's salary, royalties or other remuneration received from the University and/or the Purdue Research Foundation, or, in the case of Investigators who are not Purdue Employees, salary, royalties or other remuneration from their primary employer.
Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency or an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Income from service on advisory committees or review panels for a federal, state or local government agency or institution of higher education as defined at 20 U.S.C. 1001(a), academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.
Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
For Investigators who are not University Employees, any ownership interest in their primary employer held by the Investigator.