Conflicts of Interest in Externally Funded Projects
Faculty and students at Loyola University Chicago are encouraged to engage in externally funded research, training and public service projects. The University has a responsibility to assure its stakeholders that university activities are undertaken in a manner that is free of potential or real conflicts of interest.
Conflict of interest refers to situations in which personal or financial considerations may compromise or have the appearance of compromising an investigator’s or project director’s professional judgment in conducting or reporting on projects. For example, such conflicts may result in not only a bias affecting collection, analysis and interpretation of data, but also the hiring of staff, procurement of equipment and materials, sharing of results, choice of protocol, involvement of human participants, and the use of statistical methods. Conflicts of interest may occur when commercial sponsors of research also make significant gifts to the University or when the University acquires a financial interest in a commercial entity as a result of a licensing agreement.
The University expects that employees will conduct activities free of bias, resulting from personal, professional or financial conflicts of interest.
Employees are expected to comply with the regulations of each sponsor regarding conflict of interest. This policy does not restate sponsor regulations. Any required disclosure involving activities supported by external funding must be made before the application for funding may be submitted and shall be updated annually as long as funding or proposals for funding continue. When new reportable significant financial interests are obtained, they must also be disclosed. The University will not normally accept externally funded projects from an agency, if the primary faculty have significant financial or personal interests in the funding agency.
No employee shall, for personal gain or for the gain of others, use any information not available to the public that was obtained as a result of service to the University.
No employee shall solicit or accept for personal use, or for the use of others, a gift, favor, loan, gratuity, reward, promise of employment or any other thing of monetary value that might influence or appear to influence the judgment or conduct of the employee regarding University business or policy. Employees may accept occasional unsolicited gifts or favors, e.g. business lunches or Christmas baskets, provided the gifts or favors have a cumulative market value of under $200, are customary in the industry, and will not influence or appear to influence the judgment or conduct of the employee. Any exception to this policy, involving externally funded projects, must be approved by the Associate Provost for Research, with a statement of the reasons for the exception.
Any employee who has information concerning possible violations of this policy, shall communicate this information, confidentially and preferably in writing, to the Associate Provost for Research.
In the event of allegations of scholarly misconduct in connection with this conflict of interest policy, the Misconduct in Scholarship procedures will be followed.
In order to avoid even the appearance of impropriety:
Employees are obliged to disclose to the University any affiliation with any outside organization which may lead to the appearance of or actual conflict of interest. Such an affiliation would ordinarily include (a) the holding of the position of officer, director, trustee, partner, employee or regularly retained agent of such organization or (b) the holding of a significant financial interest in an organization that stands to benefit from research, educational or public service activities influenced by the affected employee. In addition, any affiliation with such an organization by a close relative (e.g., spouse, child, sibling, parent or parent-in-law) must also be disclosed. The Disclosure of Financial Interest Form is available here. [NOTE: Procedures for disclosing significant financial interests related to NSF- and PHS-funded projects are found at the end of this policy statement.]
Employees should also disclose any situation which has the appearance of violating this policy.
The Associate Provost for Research may take the following actions if he/she receives a Disclosure Form from an employee or receives information concerning a possible violation of this policy from a source other than the affected employee. Any discussions of potential or real conflicts of interest should be handled professionally, protecting the rights, reputation and standing of all persons affected.
The Associate Provost for Research will determine whether the potential conflict of interest requires any further action, and may take the following additional steps.
Review the Disclosure of Financial Interest form with the affected employee
Request and document additional information, if necessary, for determination of the presence or absence of a conflict of interest
Determine whether the affected employee’s supervisor should review the gathered information
Recommend and take appropriate action to resolve any apparent, potential or real conflict
Report the outcome to the Provost
[NOTE: Procedures for determining potential financial conflicts of interest (FCOI) related to NSF- and PHS-funded projects are found at the end of this policy statement.]
Financial interest is defined as anything of monetary value, including salary or payments for services (e.g. consulting fees or honoraria), equity interests (e.g. stocks, stock options or other ownership interests), and intellectual property rights (e.g. patents, copyrights, and royalties from such rights). This does not include salary or other remuneration from the applicant institution or income from public or nonprofit entities.
A significant financial interest requiring disclosure is:
an equity interest that when aggregated for the faculty, spouse and dependent children meets both of the following: exceeds $10,000 in fair market value, and represents more than a 5% ownership interest in any single entity; or
salary, royalties or other payments from a single entity that, when aggregated for the faculty, spouse and dependent children are expected to exceed $10,000 during the next twelve month period.
[NOTE: Relevant definitions related to NSF- and PHS-funded projects are found within the procedures referenced below.]