CONFLICT OF INTEREST IN RESEARCH POLICY
1. 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.
2. 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 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 Panel as a basis for guidance, possible adjustments and expeditious resolution. These matters are described below.
3. 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 objectives, financial or other.
4. 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.
5. 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.
6. The University does not accept research sponsorship predicated on the finding of predetermined research results.
7. 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.
8. 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.
9. 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.
10. 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. Counted as "significant" are paid consultantships, paid service on an advisory board, substantial equity holdings in or royalty income from the enterprise, etc. By no means does the existence of such interests necessarily imply conflict. 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."
11. Federal agencies and other sponsors have a legitimate interest in knowing of any significant financial interests that investigators may have in areas closely related to that of the project being sponsored; a legitimate interest also in the identity of other organization, if any, that may be involved in sponsorship of the project. The University requires compliance with reasonable requests for such information.
12. A Review Panel on Conflict of Interest in Research is established as a subcommittee of the University Research Board (URB). 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 or circumvent conflict of interest; and developing policy recommendations on conflict of interest in research for consideration by the URB or other appropriate University bodies. The Panel consists of six members: the Chairman of the URB and the Dean of the Faculty, ex officio; three other tenured members of the Faculty, one from Division I or 2, the others from Divisions 3 and/or 4, all three appointed by the President for staggered, renewable, three year terms; the Director of the Office of Research and Project Administration, ex officio, as secretary.
13. Every University researcher is obligated to make appropriate disclosure when, in the investigator's judgment and in the spirit of the Guidelines and 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.
14. 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 periodically takes the initiative in actively soliciting disclosure statements from investigators involved in sponsored research. There is provision on the disclosure form for a simple check mark to affirm, if that is the case, that no potential for conflict of interest is perceived by the investigator.
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