Conflict of Interest Policy for Sponsored Events

Applicability

In accordance with Federal regulations, St. Lawrence University requires that Investigators disclose any potential Conflict of Interest in relationship to a sponsored activity due to a Significant Financial Interest.  

Definitions

Investigator means the principal investigator/project director, co-principal investigators, and any other person who is responsible for the design, conduct, or reporting of research, educational, or service activities funded, or proposed for funding, by an external sponsor. In this context, the term "Investigator" includes the Investigator's spouse or domestic partner and dependent children.

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 (e.g., consulting fees, honoraria, or paid authorships for other than scholarly works; does not include salary from St. Lawrence), equity interests (e.g., stocks, stock options, or other ownership interests; does not include mutual funds and retirement accounts for which the Investigator does not directly control investment decisions), and intellectual property rights (e.g., patents, trademarks, service marks, and copyrights, upon receipt of royalties or other income related to such intellectual property rights and interests). 

Disclosure Procedure

Investigators must complete and submit St. Lawrence University’s Disclosure Statement for Investigators of Sponsored Activities to the Corporate and Foundations Relations Office before their proposal is submitted to the sponsoring agency. Disclosure Statements for sponsored activities funded by the federal government must be updated annually if the grant period extends beyond a year or when new reportable Significant Financial Interests occur. 

Review Process

Disclosure Statements will be reviewed by the Corporate and Foundation Relations Office to determine if any further review or action is required.

If the Corporate and Foundation Relations Office determines that Significant Financial Interests could affect the design, conduct, or reporting of research activities, they shall refer the matter to the university’s Corporate and Foundation Grants Review Committee to review. The committee will propose measures that will be taken to manage, reduce, or eliminate any actual or potential Conflict of Interest presented by a Significant Financial Interest

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.

The Corporate and Foundation Grants Review Committee may require that a plan for reducing or eliminating conflicts of interest be incorporated into a Memo of Understanding between St. Lawrence and the Investigator.

Managing Conflicts of Interest

Actual or potential conflicts of interest will be satisfactorily managed, reduced, or eliminated in accordance with these guidelines and all required reports regarding the Conflict of Interest shall be submitted to the sponsor prior to expenditure of any funds under an award. 

Violations

Whenever an Investigator has violated this policy or the terms of measures required by the Corporate and Foundation Grants Review Committee (including failure to file or knowingly filing incomplete, erroneous, or misleading Disclosure Statements), the violation will be handled in accordance with applicable St. Lawrence University policies, including but not limited to policies in the faculty handbook and human resources policies. In addition, St. Lawrence shall follow any and all Federal regulations regarding the notification of the sponsoring agency in the event an Investigator has failed to comply with this policy. The sponsor may take its own action as it deems appropriate.

Record Retention

Records of Disclosure Statements for all submitted proposals shall be retained by the Corporate and Foundation Relations Office in accordance with St. Lawrence University’s record retention policy. Records of Disclosure Statements and any actions taken to manage actual or potential Conflicts of Interest for all awarded grants shall be retained by the Associate Vice President for Finance in accordance with St. Lawrence University’s record retention policy.

Collaborative Projects and Subagreements

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.

Updated June 2017
Contact Carol Gable, Finance