Conflict of Interest Policy for Sponsored Events

 

In accordance with Federal regulations, St. Lawrence University requires that a principal investigator or other responsible person disclose any potential conflict of interest due to a significant financial interest in a sponsored activity to the Corporate and Foundation Relations Office before a proposal for that activity may be submitted to a sponsoring agency.    A potential conflict of interest exists when the personal or private interests of an individual, their spouse or child might lead an independent observer to reasonably question whether the individual’s professional actions or decisions are influenced by considerations of significant personal interest, financial, or otherwise.  Significant financial interest means anything of monetary value such as salary or other payments, equity interests, and intellectual property rights. 

In order to provide assurance that any potential conflict is disclosed and reviewed by the Corporate and Foundation Relations Office, principal investigators must complete and submit St. Lawrence University’s Disclosure Statement for Principal Investigators of Sponsored Activities to the Corporate and Foundations Relations Office before their proposal is submitted to the sponsoring agency.

If the Director of Corporate and Foundation Relations determines that significant financial interests could affect the design, conduct, or reporting of research activities, the Director shall refer the matter to the university’s Corporate and Foundation Grants Review Committee to review.  The committee will recommend one of the following actions:

1)         Accept the proposed sponsored project;

2)         Do not accept the proposed sponsored project;

3)         Accept the proposed sponsored project provided certain conditions or restrictions are imposed so the conflict will be managed, reduced or eliminated.  Examples of possible conditions or restrictions are:

-          Monitoring of  research by independent review;

-          Public disclosure of significant financial interests;

-          Modification of research plan;

-          Divestiture of significant financial interests; or

-          Severance of relationships that create actual or potential conflicts.

Collaborators/subrecipients/subcontractors from other organizations must either comply with this policy or provide a certification that their organizations are in compliance with federal policies in effect regarding the disclosure of investigators’ significant financial interest and that their portion of the project is in compliance with their institutional policies.

Financial disclosures for sponsored activities funded by the federal government must be updated annually if the grant period extends beyond a year or when reportable significant financial interests occur.   These will be reviewed by the Associate Vice President for Finance to determine if any further review or action is required.

Records of financial disclosures and actions taken to manage actual or potential conflicts of interest, shall be retained by the Associate Vice President for Finance for at least three years beyond the date of submission of the financial expenditures report for the project.