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Employee decision tree for disclosure of research related financial interests and entrepreneurship activities

Purdue encourages employees to engage in entrepreneurial and outside activities that may benefit the community at large and the State of Indiana. Below is a step by step guide to help employees who plan to engage in this type of activities secure required approvals and manage appropriately possible conflicts of commitment and financial conflicts of interests.

1. Determine whether you have a Reportable Outside Activity (ROA). Any work, advice or service for an entity other than Purdue University may constitute an ROA. (Review the definition of ROA at: http://www.purdue.edu/policies/ethics/iiib1.html#definitions, if needed). If you are not sure whether you have an ROA, contact your Supervisor, Department Head, or vpec@purdue.edu, for help in making your determination.

2. Determine whether you have a financial interest related to a Purdue purchase/procurement from, or contract/sub-contract to, an outside entity/company in which you have an ownership interest (i.e., instances when funds are to be transferred from Purdue to that entity). If you do, you must obtain approval from the Board of Trustees before a purchase/procurement/contract/subcontract is made.

3. If you are an Investigator on sponsored research project(s), determine whether you have a Significant Financial Interest (SFI) related to your projects (or your institutional responsibilities, if funded by PHS/NIH). Receiving more than $5,000 in compensation from, or having ownership interests in, outside entities, constitute SFIs that need to be disclosed. Definitions of SFI, Investigator and Institutional Responsibilities, can be found at http://www.purdue.edu/policies/ethics/iiib2.html#definitions. If you are not sure whether you have an SFI, contact fcoi@purdue.edu for help in making a determination.

4. If your research projects involve human subjects or living vertebrate animals, determine whether you have an SFI related to protocols you submit to IRB and/or PACUC.

5. If you are a voting member of a University Regulatory Committee (Institutional Review Boards, Purdue Animal Care and Use Committee, and/or Institutional Biosafety Committee), determine whether you have a Significant Financial Interest (or personal or professional relationship) that may reasonably appear to be related to a protocol which is to be reviewed by the Board or Committee.

6. If you are an Investigator/Entrepreneur associated with outside entities, determine whether your role in the third party creates a conflict of interest with respect to Purdue research activities and/or Institutional Responsibilities.

The university policies on conflict of commitment and reportable outside activities (COC/ROA) and individual financial conflicts of interest (FCOI) can be found at:

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