Conflict of Interest: Policies and Management

Disclosure of Significant Financial Interests for Investigators Submitting Proposals to External Sponsors

What is required?

Purdue University policy on Individual Financial Conflicts of Interest (X.2.3) requires that investigators participating in sponsored projects disclose any significant financial interests that may present an actual or potential conflict of interest in relationship to externally sponsored projects. Such disclosures of financial interest must be made prior to the submission of a proposal for funding, and Purdue's responsible official for research related conflicts of interest must develop specific mechanisms to satisfactorily manage, reduce, or eliminate any resulting actual or potential conflicts of interest that may threaten the objectivity of research prior to acceptance of an award. If a new significant financial interest arises at any time during the period after the submission of the proposal through the period of the award, a new supplemental disclosure is required. In addition, federal agencies such as DHHS and NSF have specific reporting requirement (please consult the DHHS and NSF Reporting Requirements - http://www.purdue.edu/research/vpr/rschadmin/coi/rep_req.shtml - for more information regarding reporting requirements to DHHS and NSF).

What must be disclosed?

Each investigator shall disclose all significant interests that satisfy either of the following criteria:

Significant financial interests that would reasonably appear to be directly affected (benefited or harmed) by the research or educational activities funded, or proposed for funding, by an external sponsor; or
Significant financial interests in entities whose financial interests would reasonably appear to be directly affected (benefited or harmed) by the research or educational activities funded, or proposed for funding, by an external sponsor.

Procedures for Disclosure

All investigators participating in a proposed sponsored project must complete and sign a Financial Interest Statement within one week of transmittal of any proposal to Sponsored Program Services for submission to an external sponsor. To facilitate this process for investigators, Purdue has developed a web based application to collect the Financial Interest Statements (FIS) and related disclosures.

As part of this process, all investigators on a research proposal will be notified via email that they need to fill out their FI statement using the online, web-based application. Investigators will utilize their Purdue Career Account login and password to access their online forms.

Any investigator who indicates in their FIS the existence of a “significant financial interest” related to proposed research or instructional activities must complete and sign the Research Related Significant Financial Interest Disclosure Form and then submit the signed form to the University Responsible Official in the Office of the Vice President for Research within 30 days of submission of the proposal to an external sponsor. Disclosures of research related significant financial interest should be submitted to: Dr. Peter E. Dunn, Associate Vice President for Research, Office of Research Integrity and Regulatory Affairs, Hovde Hall, Room 335.
The Office of Research Integrity and Regulatory Affairs will contact individuals who disclose significant financial interests to gather additional information necessary to assess potential conflicts of interest and draft a conflict of interest Management Plan, when necessary.
Questions regarding these instructions should be directed to Voichita Dadarlat, Assistant Vice President for Research, Office of Research Integrity and Regulatory Affairs, voichi@purdue.edu or Peter E. Dunn, pedunn@purdue.edu.

To whom does this requirement apply?

"Investigator" means a project director, a principal investigator of a research project and any other person, regardless of title or position, who has responsibility for the design, conduct or reporting of research or project results at or involving Purdue, including Employees, subgrantees, contractors, subcontractors, collaborators and consultants. In general, any individual specifically named in a proposal and any individual whose resume or curriculum vitae is appended to a proposal is an Investigator for the purposes of this policy.

What are "Significant Financial Interests"?

Financial interest
A financial interest is 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.

Significant Financial Interest
A Significant Financial Interest is a Financial Interest held by an Investigator and/or an Investigator's Dependent that reasonably appears to be related to the Investigator's Institutional Responsibilities and that consists of one or more of the following:

Remuneration (including salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, and/or an Equity Interest held in such publicly traded company, if the aggregate value of such remuneration, plus the value of the Equity Interest as of the date of disclosure, exceeds $5,000;
Remuneration (including, but not limited to, salary, consulting fees, honoraria and paid authorship) received from a non-publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, if the remuneration exceeds $5,000;
Any Equity Interest in a non-publicly traded company or business, regardless of value; and
Any Intellectual Property Rights, regardless of value.

Significant Financial Interest does not include:

An Employee's salary or royalties received from the University and/or the Purdue Research Foundation,
Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency or an institution of higher education, or
Income from service on panels for a federal, state or local government agency or institution of higher education.

Financial Conflict of Interest FAQ

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