Rules and Procedures of the Professional Researchers and Professional Specialists of Princeton University and Other Provisions of Concern to These Personnel
Last printed Fall 1996; Revised September 2006
APPENDIX D - STATEMENT ON CONFLICT OF INTEREST IN SPONSORED RESEARCH
The University Research Board is responsible for sponsored research policy and its implementation. Sponsored research policy concerns both the University's obligations to sponsors and criteria applicable to the conduct of the research.
As a non-profit private educational institution the University is involved in many complex relationships with outside organizations. In the extreme example, an outside organization could be, at the same time, a collaborator, a sponsor, and a supplier. University personnel, acting as individuals, also have a variety of outside formal and informal relationships, in many cases with the same organizations as the University. These relationships between the University, its personnel and outside organizations come together most frequently in the area of sponsored research. This complex set of relationships provides potential for either an appearance of, or actual conflicts of interest for faculty and research staff.
B. CONFLICT OF INTEREST AS A PROBLEM IN SPONSORED RESEARCH
Members of the University's research community funded by external sponsors must be concerned with conflict of interest or even the appearance of conflict of interest. The following criteria should govern individual relationships with external organizations and will help to determine whether conflicts exist:
- An individual should not benefit or expect any benefit, either directly or indirectly, by using or transmitting any information, research results, records, property, etc. which are generated, owned, controlled or in the custody of the University and which are not made generally available.
- An individual should not undertake or orient any research within the University with the purpose of serving the needs or interests of an external individual or organization, except in connection with projects financed by the same individual or organization and approved by the University.
- An individual should not influence, or attempt to influence, issue of any subcontracts or purchase orders to any firm in which the individual holds some kind of consulting or similar relationship. If there are compelling reasons for making an exception, such as the absence of an alternate source, the individual should make a full disclosure of the consulting or other relationship and the reasons making the exception.
- An individual should not influence or attempt to influence issuance of any subcontracts or purchase orders to any firm in which the individual holds a financial interest if the nature or magnitude of the subcontract or purchase order represents a significant contribution to the firms present or future business or would otherwise result in a significant indirect financial benefit to the individual.
- An individual should not accept gratuities or favors from any private firm which is or may be the recipient of a University subcontract or purchase order.
- An individual should not offer gratuities or special favors to the employees of Government agencies or of private organizations who may award contracts, grants or gifts to the University, under circumstances that might reasonably be interpreted as an attempt to influence the recipients in the conduct of their duties.
- An individual should not enter into a consulting agreement which is in conflict with the provisions of the Princeton Patent Policy or with the requirements of a sponsored grant or contract, should not accept any outside position that conflicts with his/her position within the University, and should not commit the University or a department to any course of action if necessary authority has not been delegated.
- An individual should be aware that serving as a member of a panel, on a board of directors, or in an executive position on certain non-profit organizations or government agencies could cause divided loyalty. In such cases the individual should exempt himself from discussions of research projects that may involve the University and the organization.
When a research project involves collaboration with an external organization, a subcontract for services, or the purchase of a major piece of equipment, the University Research Board must be assured that the principal investigator is involved in no conflicts of interest in relationship to the external organization. Therefore, in submitting project proposals to the URB for review the principal investigator should disclose fully the exact services being provided by any organization(s), the principal investigator's relationship(s), if any, to the organization(s) and, to the extent possible, to the responsible individuals within the organization(s) which will provide the services.