Institutional Conflicts of Interest (III.B.6)

Volume III: Ethics
Chapter B: Conflicts
Responsible Executive: Vice President for Ethics and Compliance and Executive Vice President for Research
Responsible Office: Office of the Vice President for Ethics and Compliance and Office of the Executive Vice President for Research
Date Issued: July 1, 2019
Date Last Revised: November 1, 2025

Table of Contents

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Policy Clarification

Associate Vice President for Compliance
765-496-3158 | compliance@purdue.edu

Statement of Policy

Purdue University endeavors to fulfill its mission of discovery, learning and engagement with integrity and free from any actual or perceived Institutional Conflicts of Interest. The University will manage, mitigate or eliminate identified Institutional Conflicts of Interest through established processes for disclosing, reviewing and addressing them. In each case, the University will address the Institutional Conflict of Interest (i) in a timely manner, and (ii) if it involves a contract or transaction, prior to execution, when possible.

Reason for This Policy

As a public institution, the University has a responsibility to ensure that the financial or business interests of the University and University Officials do not influence or have the appearance of influencing the University’s research, teaching, outreach or business transactions. This policy, together with the procedures referenced below in the Related Documents, Forms and Tools section, establishes the requirements for disclosing, reviewing and addressing potential Institutional Conflicts of Interest.

Individuals and Entities Affected

All University Officials, including those appointed on a temporary or interim basis, and their immediate family members (spouses and dependents).

Exclusions

There are no exclusions to this policy.

Responsibilities

Office of the Controller

• Provide information to the Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research as requested in connection with evaluating whether the University or a University Official has an Institutional Conflict of Interest related to the University’s assets.

Office of the Executive Vice President for Research

• Oversee procedures for addressing potential research-related Institutional Conflicts of Interest, including the development and monitoring of plans for managing, reducing or eliminating the conflict.
• Retain information received from Purdue Research Foundation under this policy only for the purpose of managing, mitigating or eliminating any Institutional Conflict of Interest.

Office of the Vice President for Ethics and Compliance

• Maintain a disclosure and review process for financial statements filed by University Officials.
• Oversee procedures for addressing potential Institutional Conflicts of Interest that are not related to research, including the development and monitoring of plans for managing, reducing or eliminating the conflict.
• Retain information received from Purdue Research Foundation under this policy only for the purpose of managing, mitigating or eliminating any Institutional Conflict of Interest.

Offices of Treasury Operations and of Financial Planning and Analysis

• Provide information to the Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research as requested in connection with evaluating whether the University or a University Official has an Institutional Conflict of Interest related to the University’s investments and equity interests.

Procurement/Purchasing Departments

• Provide information to the Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research as requested in connection with evaluating whether the University or a University Official has an Institutional Conflict of Interest related to the University’s contracts and purchases.

Purdue Research Foundation

• Provide information to the Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research as requested in connection with evaluating whether the University or a University Official has an Institutional Conflict of Interest related to an investment, licensing or commercialization transaction, or a gift/donation managed or facilitated by the Foundation.

Sponsored Program Services

• Provide information to the Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research as requested in connection with evaluating whether the University or a University Official has an Institutional Conflict of Interest related to a sponsored program.

University Officials

• Upon appointment and annually thereafter file a financial disclosure statement with the Office of the Vice President for Ethics and Compliance.
• Adhere to the conditions of any plan implemented to manage, mitigate or eliminate an identified Institutional Conflict of Interest.

Definitions

All defined terms are capitalized throughout the document. See the central Policy Glossary for additional defined terms.

Institutional Conflict of Interest
When an Institutional Financial Interest, or the financial interests of a University Official acting within their authority on behalf of the University, has either

1. An actual effect on the University’s teaching, outreach activities and/or business transactions, or
2. The potential to affect, or reasonably appear to affect, the University’s research.

Institutional Financial Interest
Any financial interest held by or on behalf of the University or a University Official (including the official’s immediate family members) as listed below.

For the University:

1. Royalties or other payments from licenses or other technology transfer agreements related to University intellectual property rights, when such payments are in excess of $100,000 and received within the 12-month period immediately preceding the definitive agreement covering the research in question.
2. Gifts/gifts-in-kind received from a for-profit company supporting or proposing to support a sponsored project/activity, when such payments are in excess of $1,000,000 and received within the 12-month period immediately preceding the definitive agreement covering the research in question.
3. Any gift, grant, endowment, award, or donation of money or property of any kind from a foreign source (as defined by the state of Indiana) that is located in or in any way associated with a foreign adversary (as defined by the state of Indiana), including any conditional or unconditional promise, pledge, or agreement to make a gift, endowment, award or donation, or any combination of these actions from or involving such a source.

For a University Official:

1. Royalties from licenses or other technology transfer agreements related to University intellectual property rights received within the 12-month period immediately preceding the definitive agreement covering the research in question.
2. Honoraria or gifts from an entity supporting or proposing to support a sponsored project/activity or conducting a business transaction with the University that are received within the 12-month period immediately preceding the definitive agreement covering the transaction or research in question.
3. A position that gives rise to a fiduciary duty in a for-profit company.
4. Equity or other ownership interest of more than 5% in a publicly traded company.
5. Equity or other ownership interest in a non-publicly traded company.
6. Venture or other capital financing.

University Official
An individual who, because of their position with the University, has the authority to commit substantial resources of the University or to affect the processes for the review or oversight of human subject research. Refer to Appendix A for a list of University Officials.

Related Documents, Forms and Tools

Operating Procedures for Institutional Conflicts of Interest

Website Address for This Policy

www.purdue.edu/vpec/policies/ethics/iiib5

History and Updates

November 1, 2025: Updated the definition of Institutional Financial Interest for University Officials.

September 1, 2024: Updated definition of Institutional Financial Interest to align with recently amended Indiana law.

February 1, 2023: Updated the definition of Institutional Financial Interest and position title for EVPR throughout.

November 1, 2022: Updated Appendix A.

July 1, 2020: Removed interim status from the policy.

July 1, 2019: This is the first policy to address this issue.

Appendix A

Individuals with the following titles or an equivalent title, including those appointed on a temporary or interim basis, are considered University Officials.

• President
• Provost
• CFO
• Executive Vice President
• Chancellor
• Senior Vice President
• Vice President
• Vice Chancellor
• Vice Provost
• General Counsel
• Dean
• Assistant or Associate Dean of Research
• Director of Intercollegiate Athletics
• Chief Audit Executive
• Assistant Vice President for Research
• Associate Vice President for Animal Resources
• Associate Vice President for Auxiliary Services
• Associate Vice President for Compliance
• Director of Procurement
• Comptroller
• Institutional Official, Human Research Protection Program
• Director, Human Research Protection Program
• IRB Administrator
• IRB Members