Rules and Procedures of the Faculty of Princeton University and Other Provisions of Concern to the Faculty
Last printed June 1994; Last updated May 2012
CHAPTER V: RULES AND POLICIES
The following paragraphs set forth rules applicable to members of the faculty in certain areas in which written policies have been promulgated. The policies printed here are not intended to be exhaustive or to supplant commonly held understandings in areas not covered by these paragraphs.
Complaints regarding non-academic conduct of members of the faculty should be addressed to the Dean of the Faculty. When such a complaint is brought forward, the Dean normally conducts an inquiry and, if appropriate, submits his or her findings and recommendations to the President under paragraph IV.N.1. above.
If a member of the faculty is uncertain about any of these matters, he or she should feel free to discuss them with the department Chair or with the Dean of the Faculty.
- No officer of instruction of the University shall tutor students of the University privately for remuneration during the academic year, except as he or she may be authorized by the Dean of the College.
- No officer of instruction of the University shall be permitted at any time to tutor students privately in preparation for those examinations in which the instructor himself or herself takes part, either in the way of preparing questions or reading papers.
In order to avoid conflicts of interest, it is University policy that no Faculty or staff member may initiate, or participate in, directly or indirectly, decisions involving a direct benefit, (e.g. initial employment or appointment, retention, promotion, salary, course work assignments, research funds, leaves of absence, etc. or, in the case of students, admission, grades or recommendations) to those related by blood or marriage, membership in the same household, including domestic partners, or persons with whom a Faculty or staff member has an intimate relationship. The potential for conflict of interest may also exist in close personal relationships which involve other than family relationships. The University views such conflicts of interest as seriously as it does those involving family members or blood relatives.
C. Consensual Relations with Students
Among the grounds stated in paragraph IV.N.1 above for disciplinary action is "conduct which is shown . . . substantially to impair the individual's performance of the full range of his or her responsibilities as a member of the Faculty." Whenever a faculty member has a professional responsibility for a student or could reasonably expect to have professional responsibility for the student during the student's time at Princeton, a consensual sexual or romantic relationship between the faculty member and the student raises a serious question of violation of this provision. A faculty member has a professional responsibility for a student when he or she has direct or indirect administrative, teaching or supervisory responsibility for that student.
When a sexual or romantic relationship involves individuals in a teacher-student relationship (e.g. being directly or indirectly taught, supervised or evaluated) or involves any element of coercion, harassment, bargaining for educational favors, or the like, it is a clear and most serious violation of both University and professional standards, as well as a potential violation of state and federal anti-discrimination statutes. Any sexual or romantic relationship between teacher and student is bound to impinge upon the teacher-student relationship, not only with regard to the student involved but also in relationship to his or her peers, who may perceive favoritism or unequal treatment by the faculty member. Consensual relationships with students can also create immediate problems of conflict of interest (addressed by the University's policy on nepotism, Section V.B.) and of sexual harassment (Section V.D.) which may also expose the faculty member to charges of misconduct and to disciplinary action.
Complaints regarding non-academic conduct of members of the Faculty should be addressed to the Dean of the Faculty. When such a complaint is brought forward, the Dean normally conducts an inquiry and, if appropriate, submits his or her findings and recommendations to the President under paragraph IV.N.1 above.
D. Discrimination, Harassment, and Sexual Misconduct
1. Princeton University is committed to maintaining an environment free of all forms of harassment, discrimination, and sexual misconduct. All members of the Faculty, academic professionals (Professional Librarians, Professional Researchers, Professional Specialists) and non-academic staffs are responsible for helping to insure a community free of such prohibited conduct. The information provided below describes the University’s policies prohibiting discrimination, harassment, and sexual misconduct. It also explains the processes through which complaints by or against members of these groups may be brought forward, as well as descriptions of the central roles played by "harassment resolution facilitators" and "confidential counselors" in the resolution process. The full text of the University’s Nondiscrimination/Anti-Harassment Policy and Procedures, prohibiting discrimination and harassment, can be accessed at http://www.princeton.edu/diversity/policy/antiharassment/. The full text of the University’s statement prohibiting sexual misconduct can be accessed at http://www.princeton.edu/pub/rrr/part1/index.xml#comp12.
Complaints of discrimination, harassment, and sexual misconduct against students, including graduate students serving as Assistants in Instruction (AIs), are covered by student disciplinary procedures administered by the Faculty Committee on Discipline.
2. Discrimination, harassment, and sexual misconduct are serious violations of University policy as well as violations of federal and state law. Title IX of the Education Amendments of 1972 prohibits discrimination on the basis of sex in education programs receiving federal funds. Title VII of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, religion, sex, and national origin in employment practices. The New Jersey Law Against Discrimination prohibits discrimination in employment practices on bases such as race, color, religion, sex, national origin, sexual orientation, disability, age and gender identity.
3. As required by law, the University has devised and adopted appropriate procedures for addressing and resolving concerns and complaints of discrimination, harassment, and sexual misconduct by members of the campus community. Under the law, employers and supervisors (i.e., individuals with assigned supervisory duties over employees) have a responsibility to report claims of discrimination, harassment, and sexual misconduct to the appropriate individuals designated in these procedures. "Supervisors" in a university context include Chairs of departments who supervise Faculty, and all individuals who have been assigned formal supervisory duties over employees. For example, apart from the Chair of a department, Faculty do not normally supervise each other, or, in the relevant sense, students. They do, however, often have supervisory responsibility over members of support staff or members of other professional staffs, and are thus under an affirmative obligation to respond to incidents of discrimination, harassment, and sexual misconduct in their areas of supervisory responsibility. Supervisors in the sense just defined are not only responsible for reporting incidents when they receive a specific complaint or concern alleging improper activity on the part of a member of their staff, but they also have a duty to report such matters that come to their attention informally (e.g., by witnessing or otherwise learning of such incidents). Indeed they may be held responsible for not having acted upon matters about which they reasonably should have known.
4. Discrimination against a person on the basis of his/her race, creed, color, sex, gender identity, age, national origin, ancestry, religion, physical or mental disability, veteran's status, marital or domestic partnership status, affectional or sexual orientation, or any other characteristic protected under law is unlawful and violates University policy. The University expects all members of the campus community, as well as its visitors, to be treated equally based on merit in all aspects related to its educational programs and activities, and in all aspects related to employment.
Listed below are examples of conduct that can constitute discrimination if based on an individual’s protected characteristic. This list is not all-inclusive; in addition, each situation must be considered in light of the specific facts and circumstances to determine if discrimination has occurred.
- Singling out or targeting an individual for different or adverse treatment (e.g., more severe discipline, lower salary increase) because of his or her protected characteristic
- Failing or refusing to hire or admit an individual because of his/her protected characteristic
- Terminating an individual from employment or an educational program based on his/her protected characteristic
a. Harassment is defined as unwelcome verbal or physical behavior which is directed at a person because of his/her race, creed, color, sex, gender identity or expression, age, national origin, ancestry, religion, physical or mental disability, veteran’s status, marital or domestic partnership status, affectional or sexual orientation or other protected characteristic, when these behaviors are sufficiently severe and/or pervasive to have the effect of unreasonably interfering with an individual’s educational experience or working/living conditions by creating an intimidating, hostile, or offensive environment.
Listed below are examples of behaviors that can constitute harassment. This list is not all-inclusive; in addition, each situation must be considered in light of the specific facts and circumstances to determine if discrimination has occurred.
- Unwelcome jokes or comments about a legally protected characteristic (e.g., racial or ethnic jokes);
- Disparaging remarks to a person about a legally protected characteristic (e.g., negative or offensive remarks or jokes about a person's religion or religious garments);
- Displaying offensive posters or pictures about a legally protected characteristic
- Electronic communications, such as e-mail, text messaging and internet use, that violate this Policy; and
b. A description of those behaviors that can constitute sexual misconduct and the full text of the University’s statement prohibiting sexual misconduct can be accessed at http://www.princeton.edu/pub/rrr/part1/index.xml#comp12.
5. Complaints of discrimination, harassment, and sexual misconduct will be treated with the maximum possible degree of confidentiality. Confidential resources (including the chaplains in the Office of Religious Life, the Ombuds Officer, and other individuals identified as such) are not authorized to engage in fact-finding or take action on behalf of the University. If after speaking with a confidential resource an individual does not wish to initiate a complaint, the confidential resource will take no action. If an individual does wish to make a complaint, the confidential resource will put the individual in touch with an appropriate University administrator (i.e., a "discrimination/harassment resolution facilitator,") who can also provide counseling and initiate actions to remedy complaints of discrimination, harassment, and sexual misconduct (see Section 6 below).
a. Fear of retaliation should not be a barrier to reporting incidents of discrimination, harassment, or sexual misconduct. Retaliation in any form will not be tolerated and is, in addition to the initial incident, subject to University disciplinary procedures.
b. The Director for Equal Opportunity Programs, in collaboration with the Office of General Counsel and the Director of the Sexual Harassment/Assault Advising, Resources and Education Office (SHARE), and other resources as appropriate, provides assistance and training to individuals and offices relating to discrimination, harassment, and sexual misconduct, as well as information about procedures for pursuing complaints of such behaviors. The Director for Equal Opportunity Programs is also responsible for maintaining records of internal complaints under these policies.
c. All Faculty and academic professionals, current and new, are expected to complete an on-line (computerized) sexual harassment prevention learning module. The purpose is to make employees aware of their rights and responsibilities and to ensure they receive consistent information on the University’s policies prohibiting discrimination and harassment.
d. Individuals who have a responsibility under these University policies for taking action to discover and to stop discrimination, harassment, and sexual misconduct do so as agents of the University. Accordingly, these individuals will be defended legally by the University in case of a lawsuit for their actions taken in good faith in accordance with University policies, even if mistaken.
6. Any individual who has information about or believes that he or she might be the victim of a specific act or a pattern of behavior falling within the above definitions of discrimination, harassment, or sexual misconduct carried out by a member of the University community, should discuss the matter with one of the discrimination/harassment resolution facilitators designated in the University’s Nondiscrimination/Anti-Harassment Policy and Procedures. In addition, any individual having information about such acts or patterns of behavior in a supervisory capacity (i.e., where the alleged perpetrator is someone whom he or she supervises in the sense explained in Section 3 above) is under an affirmative duty as part of University employment to act upon such information by bringing it to the attention of one of these designated administrators. She or he should not under such circumstances try to "handle the matter" on her or his own.
These resolution facilitators, listed below, can provide information, answer questions, and receive complaints (both formal and informal) about discrimination, harassment, and sexual misconduct. They also may refer individuals to resources within the University; in emergencies they will obtain assistance to intervene directly to protect the safety of individuals; in appropriate situations they may themselves seek to resolve conflicts between a complainant and respondent. They also may assist complainants in deciding whether to submit a written complaint, including the option to utilize the University’s electronic complaint form, which may be found at http://www.princeton.edu/dof/policies/forms/misc_forms/. Note: in some instances the University may be obligated to act without the consent of the complainant.
The following resolution facilitators stand ready to assess concerns, engage in fact-finding, and will seek to resolve the matter at the lowest possible level:
- For Undergraduate Students: Associate Deans of Undergraduate Students, or Directors of Student Life
- For Graduate Students: Associate Deans of the Graduate School
- For Faculty or Academic Professionals: Associate Deans of the Faculty
- For Human Resources Staff: Senior Human Resources Managers, or Director of Client Services
- For Princeton Plasma Physics Laboratory Staff: Director of Human Resources
If the complainant fails to achieve satisfactory results through this informal means, however, he or she may still initiate a written formal complaint.
7. An individual who decides, usually after consultation with one of the resolution facilitators, to make a written complaint against a member of the Faculty or a member of the other staffs alleging a violation of the University’s policies prohibiting discrimination, harassment, or sexual misconduct may do so as follows:
a. Complaint Reporting
Any member of the University community who believes she/he has been subjected to or has observed discrimination, harassment, or sexual misconduct may submit a written complaint. A complete list of University resources with contact information can be found at http://www.princeton.edu/diversity/harassment/.
The written complaint should identify the parties involved; describe the behavior, including when and where it occurred; and identify by name or description any witnesses. Written complaints should be treated as confidential and should be provided directly and only to one of the appropriate designated administrators listed at http://www.princeton.edu/diversity/harassment/.
b. Interim Steps
When appropriate, prior to or during the investigation, the Provost’s Office may recommend to the appropriate University official that interim steps be taken to protect the safety and well-being of members of the University community.
c. Investigation Process
The purpose of the investigation is to gather facts relating to the incident(s) set forth in the complaint and to determine whether the alleged behavior occurred and, if so, whether it constitutes a violation of University policy. The complaint process allows individuals to submit their complaint to one of many offices, although the requisite fact finding in the case of a faculty member will typically be conducted by DOF. The investigator (or co-investigators, as necessary) will conduct a fact-finding inquiry that may include written statements, interviews and any other sources the investigator deems appropriate. During the course of the investigation, the investigator may receive counsel from the Provost’s Office, the Office of General Counsel, or other parties as needed.
Note: Princeton University expects its faculty, staff and students to cooperate fully in the investigation process. An individual who chooses not to cooperate may be subject to discipline.
Note: Adversarial hearings, including confrontation, cross-examination by the parties, and active advocacy by attorneys or other outside advocates, are neither appropriate nor permitted during the investigation process.
d. Complaint Resolution
At the conclusion of the investigation, a determination will be made whether any allegations in the complaint were substantiated and whether University policy was violated. A written report will be submitted to the appropriate Dean (in most instances the Dean of the Faculty) or Vice President (in most instances the Vice President for Human Resources) and to the Provost’s Office.
The Dean/VP to whom the report is submitted may accept the report or return the report for further investigation. The Dean/VP or their designee will, for both parties involved (the person who filed the written complaint as well as the person whose behavior is being investigated), summarize the findings (see range of findings below).
Finding of “No Violation” of the University’s policies prohibiting discrimination, harassment, or sexual misconduct
If there is a determination that the behavior investigated did not violate University policy, both parties will be so informed. Neither party may appeal such a finding. If retaliatory behavior occurs after the issuance of this determination, either party may bring a new complaint.
Finding of “Inappropriate Behavior Not Rising to the Level of a Violation” of the University’s policies prohibiting discrimination, harassment, or sexual misconduct
There may be a determination that the behavior was inappropriate and unprofessional but did not rise to the level of violating University policy. Such inappropriate behavior may merit discipline, ongoing monitoring, coaching, or other appropriate action. Neither party may appeal such a finding. If retaliatory behavior occurs after the issuance of this determination, either party may bring a new complaint.
Finding of “Violation” of the University’s policies prohibiting discrimination, harassment, or sexual misconduct
If there is a determination that the behavior did violate University policy, the VP/Dean, in consultation with the appropriate manager or department head, will determine the appropriate corrective actions to be taken. In addition, where appropriate, the Dean/VP/Provost may implement measures to ensure that the person who filed the complaint is not subjected to further harassment, and to remedy the effects of any harassment that may have occurred. Remedial steps, at the discretion of the University, may include, but are not limited to, ongoing monitoring, counseling or training, separation of the parties, and/or discipline of the accused, including a written warning, financial penalty, suspension, demotion or termination in accordance with University policy. The process for appealing such a finding is set forth in item 8 below.
The University’s ability to discipline an individual who is not an employee or student (such as a vendor or contractor) is limited by the degree of control, if any, the University has over the alleged harasser. Nonetheless, the University will seek to take appropriate action in response to violations of this policy.
As it relates to tenured faculty, if the complaint was sustained, the Dean of the Faculty will then recommend appropriate action to the President, including any appropriate penalty in accordance with University rules and regulations. The Dean of the Faculty will inform the complainant and respondent of the findings and any action taken or penalty imposed. If the complaint is sustained, reference to the determination will be discreetly recorded in the respondent’s personnel file. With regard to issues of confidentiality of faculty files and records, the Dean of the Faculty will follow the same procedures as the Committee on Conference and Faculty Appeal.
8. Faculty members found to have violated the University’s policies prohibiting discrimination, harassment, or sexual misconduct may, consistent with the Rules and Procedures of the Faculty, file a written appeal with the Committee on Conference and Faculty Appeal, provided the appeal involves the “dismissal or the suspension . . . or any question of unfair treatment in relation to the appointment, reappointment, or academic duties or privileges.”
Academic Professionals found to have violated the University’s policies prohibiting discrimination, harassment, or sexual misconduct may, consistent with the Rules and Procedures of the Professional Researchers and Specialists and Rules and Procedures of the Professional Library Staff, submit a written request for reconsideration to the Dean of the Faculty on the grounds that: (i) there exists substantial relevant information that was not presented, and reasonably could not have been presented during the investigation, or (ii) the imposed penalty does not fall within the range of penalties imposed for similar misconduct.
Appeals concerning dismissal or suspension, or procedural unfairness will be heard by the Promotions, Continuing Appointment and Review Committee for Professional Librarians or the Committee on Appointments and Advancements for the Professional Researchers and Professional Specialists, as appropriate.
E. Use of University Identification
- By resolution of the Board of Trustees, members of the University sending communications to the public press on subjects lying outside their particular field are requested not to use the name of the University.
- Except with the formal consent of the President of the University, no one connected with the University shall enter into any agreement with any firm or enterprise whereby the name "Princeton" shall be used in advertising, publicity, etc., nor shall furnish to firms or enterprises material for advertising, publicity, etc., in which the name "Princeton" appears.
F. Confidentiality of Student Records
It is the policy of Princeton University that all student and alumni records are private, confidential documents. Information from them is not to be disclosed (except to authorized University personnel, for internal use) to any person, organization, or agency without the consent of the individual to whom they pertain. This policy shall apply to all such records, wherever they may be lodged. The University Policy originally adopted to implement the foregoing statement has been affected in important ways by The Family Educational Rights and Privacy Act of 1974. [A current statement of University regulations may be obtained from the Office of the Secretary.]
As an extension of the general policy set forth above, Faculty members are expected to treat with discretion any information concerning a student's political, religious, or social opinions and beliefs as revealed in classroom exchange or discussion, in course essays, conferences or in other contexts of the educational process. This policy is in no way intended to discourage Faculty members from making professional judgments of students' academic capacities or performance in response to reasonable requests, but to safeguard the individual's right to privacy and to protect the student-teacher relationship. Faculty members are invited to cite this document as a statement of official University policy in response to requests for information that appear to infringe upon the principles of academic freedom and individual privacy.
G. Misconduct in Research
The University is committed to high scholarly standards in the substance of research and to high ethical standards in the conduct of research. Safeguards on both fronts are embodied in the best traditions of disinterested scholarly inquiry, including skepticism, independent cross checks, and a sense of personal responsibility. These traditions presuppose that one's colleagues are honorable, even if occasionally mistaken: room has to be left open for intellectual risk-taking and honest error. However, any serious indication of research misconduct calls for systematic institutional response. Members of the Princeton community have a duty to foster a climate that encourages ethical conduct of scholarly research. They also have a responsibility to report if ever they encounter serious indications of misconduct in research. Reporting such concerns in good faith is a service to the University and to the larger academic community. The University is committed to maintaining an environment which enables and encourages such service. The University prohibits retaliation of any kind against a person who, acting in good faith, reports or provides information about suspected or alleged misconduct in research.
"Misconduct in research", as understood here, includes, but is not limited to, fabrication or falsification of data, plagiarism, interference with the integrity of the work of others, or misappropriation of the ideas of others in the proposing, conducting and reporting of research. The procedures adopted for dealing with possible incidents of misconduct must be sensitive to the personal reputations and careers of the person bringing the allegation of misconduct, of the person against whom the allegation is directed, and of others caught up in the events. Confidentiality in the proceedings has to be respected throughout, to the maximum extent possible. Procedures must be expeditious and fair. It is important that a written record be kept covering all phases of the proceedings. These records will be kept for at least three years. Members of the inquiry and investigative committees must be selected with a care for their impartiality and personal distance from the principals. Princeton University will comply with reporting requirements of any relevant federal regulations.
- The responsibility for pursuing allegations of misconduct in research rests with the Dean of the Faculty. If a graduate student is involved as one of the principals, the Dean of the Faculty will consult throughout with the Dean of the Graduate School.
- An inquiry is initiated upon submission to the Dean of allegations of misconduct in research. The allegations should be accompanied by or included within a written statement which lays out the allegations and evidence. The person raising the allegations (the "claimant") is expected to be available early on for a confidential, personal discussion with the Dean. The aim in this is not to assess the accuracy of the allegations, except insofar as they may be patently mischievous or malicious, but to clarify the issues and determine whether the case falls properly under the heading of "misconduct in research". If it does, the Dean will soon thereafter form a small ad-hoc committee to carry out a preliminary inquiry. The committee will be expected to report to the Dean in writing within 90 days. The Dean and, as necessary, the ad- hoc committee, will make every effort to assess the claims fully and fairly even in cases where the claimantchooses to remain anonymous, for example, by presentingthe allegations via the University’s hotline (www.princeton.edu/compliance/hotline). In some such cases, however, the Dean or the ad-hoc committee may not be able to make an appropriate assessment of the matter.
- At the outset of the preliminary inquiry, the person against whom the allegations are raised (the "respondent") must be provided by the Dean with a written statement laying out in full the charges, evidence, membership of the inquiry panel, and, with permission of the claimant, the identity of the claimant. At the conclusion of the preliminary inquiry, the respondent will be provided a copy of the inquiry report. Any comments made will become a part of the record and will be considered in deciding whether to proceed to a formal investigation.
- If the committee believes that its findings warrant a formal investigation and, in the case of an anonymous complaint, are capable of being formally investigated despite the anonymity of the complainant, the Dean will form an appropriate investigative panel and inform the respondent as to its membership within 30 days. The panel must include two members of the standing University Research Board, one of whom will normally serve as Chair of the panel. It may include members from outside the University community. If government-sponsored research is involved, the University will inform the appropriate agencies in as confidential manner as possible.
- Unless there are extenuating circumstances requiring a longer process, the investigating committee will be expected to come to a conclusion and report its findings to the Dean, in writing, in no more than three months. The reports of the investigating committee will be made available to the respondent. Any comments on the report by the respondent will be considered by the Dean before the final decision is made. If the allegations of misconduct are not sustained, the case must be dropped, and nothing of it may appear in the personnel record of the respondent or claimant. The claimant may be advised by the Dean that the matter is concluded, and the allegations not sustained.
- If the respondent acknowledges misconduct, or if the Dean accepts a finding of misconduct by the investigating committee, the conclusions and disciplinary recommendations of the Dean will be forwarded to the President for decisions and implementation, subject to standard University grievance protections. If misconduct has occurred, the University must make every reasonable effort to reach and inform journal editors, research collaborators and other parties affected by the misconduct and, in the case of sponsored research, the sponsoring organizations.The claimant may be advised by the Dean that the matter is concluded, misconduct in research was found to have occurred, and appropriate responsive steps have or are being taken by the University.
H. Campus Disruptions
Free speech and peaceable assembly are basic requirements of the University as a center for free inquiry and the search for knowledge and insight. These rights involve a concurrent obligation on the part of all members of the University to maintain on the campus an atmosphere conducive to scholarly pursuits and to respect the rights of all individuals.
Demonstrations and the distribution of leaflets, statements, or petitions therefore are permitted on the campus unless, or until, they disrupt regular and essential operations of the University or significantly infringe the rights of others. On the same grounds, the campus is open to speakers whom students or Faculty wish to hear and to recruiters for agencies and organizations in whom student or Faculty have an interest.
It is a violation of these policies for a member of the Faculty, staff, or student body to prevent the orderly conduct of a University function or activity, such as lectures, meetings, interviews, ceremonies, and public events; or block the legitimate activities of any person on the campus or in any University building or facility. Activities which exceed these guidelines, if persisted in after due warning, will subject the participants to disciplinary and, if need be, legal action.
The University cannot be content merely to tolerate inquiry and discussion; it has an obligation to ensure and protect them.
I. Conflicts of Interest in Research
- Research activity in the University is dedicated to the advancement, preservation and dissemination of knowledge; instruction of undergraduate, graduate and postdoctoral students; advancement of the public interest and public welfare. Research dedicated to these ends may incidentally generate financial benefits to individual investigators and to the University, for example, through patents and licensing. This is to be welcomed. However, the prospect of such gain cannot be allowed to govern the selection and conduct of research projects. Choices concerning the nature and orientation of research must be based on University values, which include intellectual importance, educational merit and public benefit. It is thoroughly consistent with these values, indeed it is both necessary and desirable, for the University to seek outside support from government, industry, foundation and private sponsors. Sponsored projects should reflect a coincidence of research interests on the part of sponsors and University.
- Outside professional, financial and entrepreneurial activities of individual faculty and staff can contribute to University goals and provide valuable public and personal benefits as well. Primary commitment must however be devoted to the University. External interests and activities have to be ordered so as to minimize any risk of conflict with University objectives and values. It is not possible to lay down a precise and comprehensive set of rules on conflict of interest, even when the focus is narrowed to the research side of University life. A representative set of markers is nevertheless provided below. A Review Panel on Conflict of Interest in Research (Review Panel), as set forth in paragraph I.13 below, is established to monitor and deal with issues of conflict. Faculty and staff are counted on, in the first instance, to monitor their own activities. Whenever they perceive that the question of conflict might arise, they are expected to disclose the relevant facts to the Review Panel as a basis for guidance, possible adjustments and expeditious resolution. These matters are described below.
- Student participation in research is a central educational goal of the University. The selection and involvement of students must therefore at all times be governed primarily by consideration of the students' own educational goals as well as the legitimate needs and objectives of the research project. Faculty and staff must at all times scrupulously avoid providing research guidance and facilities to students with the dominant aim of serving their own outside professional, financial and/or entrepreneurial activities and objectives.
- Open communication of research findings is an important University value. Outside sponsorship or other associations should not be a basis for inhibiting the publication or sharing of information. In the case of sponsored research, University researchers must retain full rights concerning the timing and content of publications, apart from those safeguards established by the University to protect privacy, proprietary information and patentable inventions.
- Research data and materials owned by or in the custody of the University, if they are to be made available externally, must be made generally available. In no case can the transfer of data or materials be made for reasons of personal gain, except in accordance with University policy on patents and copyright.
- The University does not accept research sponsorship predicated on the finding of predetermined research results.
- Except in the most incidental of ways, members of the University community should not use University research or administrative facilities to pursue personal business or commercial consulting activities.
- Research within the University may not be undertaken or oriented with the purpose of serving the interests of outside persons or organizations unless there is University approval and, typically, appropriate financial support from the same persons or organizations.
- Members of the University who enter into external consulting or other agreements must take care that these are not in conflict with the provisions of Princeton's patent policy, its obligations under any sponsored grant or contract, or any other policies of the University.
- The risk of conflict of interest, or serious appearance of conflict, can arise when a University investigator (or immediate relative or household member) has significant financial interests in an external enterprise engaged in activities closely related to the investigator's line of University research. It is the policy of the University to require faculty to complete an Annual Disclosure Form designed to identify any potential conflicts of interest arising from significant financial interests so that they may be appropriately managed. The University defines "significant financial interest" to include paid consultantships, paid service on an advisory board, substantial equity holdings in or royalty income from the enterprise. By no means does the existence of such interests necessarily imply a conflict of interest. Nevertheless, where there are such interests, the investigator is obligated to provide full and current disclosure to the Review Panel. In exercising their judgment, members of the University are urged to tilt toward disclosure rather than nondisclosure in cases where they are unsure whether or not their outside financial interests rise to the level of "significant."
- Federal agencies funding research at the University have a legitimate interest in ensuring that the design, conduct and reporting of such research will be free from bias resulting from an investigator’s financial conflicts of interest. Often these federal agencies have specific regulations requiring certain disclosure of financial interests by principal investigators and key personnel applying for and working on federally funded research. The reporting requirements of federally funded research may be different than those ordinarily required by the University. In those cases, the University will provide guidelines to assist Investigators in understanding their obligations as well as disclosure forms.
- Every University researcher is obligated to make appropriate disclosure as required by federal regulations or when, in the investigator's judgment and in the spirit of general University standards, there is a risk of conflict of interest or serious appearance of conflict. What is called for in such cases is full and current disclosure of all interests that bear on the particular instance of conflict. Wider disclosure of personal interests beyond that is not sought.
- A Review Panel on Conflict of Interest in Research (Review Panel) is established as a committee reporting to the Dean for Research. The Panel is charged with receiving and analyzing disclosure material; proposing to the investigator suitable adjustments in project arrangements when these are deemed necessary to remove, minimize, or manage conflicts of interest; and developing policy recommendations on conflicts of interest for consideration by the URB or other appropriate University bodies. The Panel consists of ten members: the Dean for Research as chair, Dean of the Faculty, Dean of the Graduate School, Dean of the School of Engineering and Applied Sciences, General Counsel, and the Director of the Office of Research and Project Administration, ex officio; three other tenured members of the Faculty, one from Division I or II, and two from Divisions III and/or IV, all three appointed by the President for staggered, renewable, three year terms; and the Director of the Office of Technology Licensing, ex officio, as secretary.
- Where external sponsorship of research is involved, there can be extra sensitivities concerning the potential for conflict of interest and, especially in the case of government sponsorship, conformity with agency regulations. For these reasons, the Review Panel reviews the annual conflict of interest disclosure statements from investigators involved in sponsored research.