Financial Conflict of Interest FAQ
What is a Financial Conflict of Interest (FCOI)?
Financial Interest - Any interest that will, could or is intended to lead to a profit or an ascertainable increase in the income or net worth of an Employee and/or a Dependent. Such a profit or increase in income or net worth could be realized through the receipt of anything of monetary or potential monetary value, including, but not limited to, payments of any kind (e.g., salary, consulting fees, honoraria, gifts, dividends, distributions, rent, paid authorship, etc.), Equity Interests, an increase in the value of real estate or Equity Interests, or Intellectual Property Rights.
Employee - Each employee of Purdue University, wherever located and whether full-time or part-time, including, but not limited to, all executive officers, faculty and staff.
Dependent - An Employee's spouse, Domestic Partner or unemancipated child(ren), including stepchildren and adoptees, under the age of 18, or anyone who receives more than one-half of his or her financial support during a year from an Employee.
Domestic Partner - A same sex domestic partner of an Employee who is eligible for same sex domestic partner benefits under University policy.
Financial Conflict of Interest (FCOI) - Situations where an Employee's Financial Interest (including an Investigator's Significant Financial Interest, where applicable) compromises, or could appear to compromise, his or her judgment or ability to carry out the Institutional Responsibilities associated with his or her appointment or employment. A Financial Conflict of Interest may take many forms, but in general arises when an Employee in a relationship with an outside person or organization is in a position to influence the University’s business, research or decisions in ways that could lead directly or indirectly to financial gain for the Employee or the Employee’s Dependents or could give an improper advantage to others to the detriment of the University.
When applied to an Investigator, Financial Conflicts of Interest occur in situations in which such Investigator's Financial Interest (including Significant Financial Interest) compromises, or could appear to compromise, his or her professional judgment regarding the design, conduct or reporting of research or if such Financial Interest could directly and significantly affect the design, conduct or reporting of research. The bias such conflicts may conceivably impart not only affects collection, analysis and interpretation of data, but also the hiring of staff, procurement of materials, sharing of results, choice of protocol, involvement of human participants and the use of statistical methods.
Financial Conflicts of Interest also include the use of University facilities, personnel, equipment, IT Resources (as defined in the IT Resource Acceptable Use Policy (V.4.1)), confidential information or other resources for purposes that could lead directly or indirectly to financial gain for the Employee and/or his or her Dependents.
Who is Responsible for Managing FCOI?
Responsibility of all employees of Purdue University
All employees of Purdue University are required to disclose, as required by the University Policy on Individual Financial Conflicts of Interest, any and all Financial Interests that he, she or a Dependent has in University activities or transactions. Such disclosures must be made as far in advance of the contract, purchase, procurement, investment or loan as possible and may be made on an annual basis with respect to particular types of contracts or purchases of goods or services that the University makes on a repetitive basis from a particular vendor.
Upon request by the COI Officer, confirm the accuracy of and sign each Conflict of Interest Disclosure Statement prepared by the COI Officer for transmittal to the Board of Trustees and the Indiana State Board of Accounts.
Comply with the requirements of any management or mitigation plan approved by the Conflicts Committee.
How do I add a new SFI Disclosure in the Proposal Driven Disclosure online application?
If you are a Purdue employee who has previously been identified as an Investigator on a research proposal submitted to an external sponsor, you can add a new Research Related Significant Financial Interest Disclosure (RRSFID) in the Proposal Driven Disclosure (PDD) online application, by logging into the PDD (using your Purdue career account credentials) at:
Once logged in, at the top of the webpage you will see two tabs, My Proposals and My Disclosures. Please click on the My Disclosures tab; you will be taken to your Disclosures page headlined:
At the top of that page, you will see a list of your Research Related Significant Financial Interests (if you already have disclosed SFIs) and a link (in blue text), “Add New Research Related Significant Financial Interest Disclosure”. Click on the (blue) link and you will be taken to a blank RRSFID form. Please fill out all the required fields, sign the form using your career account credentials, and then click on the “Add Disclosure and Submit Signature” button at the bottom of the page. One RRSFID Form must be completed for each entity in which the Investigator has a Significant Financial Interest. Should you need to fill out more than one disclosure form, please repeat the process by clicking again on the link “Add New Research Related Significant Financial Interest Disclosure”.
If you are a new Purdue Employee or have never been an Investigator on a Purdue proposal submitted to an external sponsor, please send an email message to firstname.lastname@example.org with your request to be added to the PDD application. Once you receive an email confirmation that you have been added to the system, please follow the steps outlined in 1) above.
When you finish completing your disclosure(s), you can review your portfolio of proposals by clicking on the My Proposals tab at the top of the page.
When you complete your work, please logout by clicking on the Logout button at the upper right corner of the webpage.