Individual Financial Conflicts of Interest FAQs

Capitalized terms are defined in the policy. Please refer to the Definitions section.

1. Why does Purdue need an Individual Financial Conflicts of Interest policy?
2. What is a Financial Conflict of Interest?
3. Who is required to disclose their Financial Interests?
4. Do I have to disclose all my Financial Interests?
5. Who is considered a Dependent under this policy?
6. What is the difference between a Financial Interest and a Significant Financial Interest?
7. If I’m not sure whether I need to submit a Conflict of Interest Disclosure Statement, whom should I contact for clarification?
8. When do I file a Conflict of Interest Disclosure Statement?
9. Where do I find the Conflict of Interest Disclosure Statement?
10. Where do I send my completed statement(s)?
11. I submitted a Conflict of Interest Disclosure Statement; when can I expect to receive a response?
12. What happens if the COI Officer determines that there is a Financial Conflict of Interest?
13. I completed a Conflict of Interest Disclosure Statement last year. Why do I have to complete one again this year?
14. I submitted a Conflict of Interest Disclosure Statement at the beginning of the year and now I will be the director for a new sponsored project. Do I have to submit another form?
15. If I don’t file a Conflict of Interest Disclosure Statement, what are the consequences?
16. What if I am not satisfied with the decision regarding the existence of a Financial Conflict of Interest or the terms of a conflict management plan?
17. Does this policy prevent me from having my own business?
18. I am a named beneficiary of a gift in support of my work at the University. Is there anything I need to do to comply with this policy?
19. I have an invention that will be licensed through OTC. Does this policy require me to do anything?
20. When completing a Research Related Significant Financial Interest Disclosure Form, does a significant financial interest include remuneration from a nonprofit organization?

Q 1. Why does Purdue need an Individual Financial Conflicts of Interest policy?

The Individual Financial Conflicts of Interest policy:

• Promotes the University’s basic value of integrity in our academic, research and business endeavors.
• Provides a means for Purdue and those who work for the University to comply with state regulations regarding financial conflicts of interest.
• Complies with federal regulations pertaining to the reporting of financial interests and management of potential conflicts.

Q 2. What is a Financial Conflict of Interest?

A Financial Conflict of Interest occurs when an employee’s Financial Interest (including an Investigator’s Significant Financial Interest) compromises, or appears to compromise, his or her judgment or ability to carry out the professional responsibilities associated with his or her appointment or employment at Purdue University.

In general, a Financial Conflict of Interest arises when an employee 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.

Q 3. Who is required to disclose their Financial Interests?

Each employee of Purdue University, wherever located and whether full time or part time, must disclose all known Financial Interests that he/she or a dependent has. Additionally, Investigators must disclose any Significant Financial Interests that they or their dependents have relative to a proposed sponsored project.

Q 4. Do I have to disclose all my Financial Interests?

Only certain Financial Interests are required to be disclosed. Employees must disclose any known Financial Interests that they or their Dependent(s) have in any of the following:

• Any University purchase or procurement of goods or services (whether or not pursuant to a formal contract) or in any investment or loan made by the University.
• Proposals that are submitted to external sponsors for funding.
• Protocols for research that are submitted for review and approval by a Regulatory Committee (or to a subcommittee).
• Any agreement relating to University technology or other intellectual property that is or will be subject to negotiations between OTC and any third person or entity.
• A donor that contributes a monetary gift or gift-in-kind designated to be in support of the Employee’s scholarly activities.
• For an Employee who is a member of a Regulatory Committee, any Financial Interest that he or she has in any research protocol submitted to that Regulatory Committee (with the Employee also recusing himself or herself from the review process regarding such protocol).
• For an Employee who is an Investigator, any Significant Financial Interest that he or she has not already disclosed as a Financial Interest.

Q 5. Who is considered a Dependent under this policy?

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.

Q 6. What is the difference between a Financial Interest and a Significant 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. Any employee of Purdue University may hold Financial Interests.

Only PIs and Investigators are subject to the guidelines regarding Significant Financial Interests. Significant Financial Interests are interests that are related to the Investigator’s Institutional Responsibilities and meet at least one of the following criteria:

• Remuneration (including salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a publicly traded company during the 12-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 12-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.

Q 7. If I’m not sure whether I need to submit a Conflict of Interest Disclosure Statement, whom should I contact for clarification?

Questions about the policy and how it applies to your situation can be directed to the Office of the Vice President for Ethics and Compliance by calling 765-494-5830 or emailing compliancec@purdue.edu.

If your questions are related to a sponsored research project you can contact the Office of the Vice President for Research by calling 765-494-6840 or emailing fcoi@purdue.edu.

Additional campus specific contacts are included in the Contacts section of the policy.

Q 8. When do I file a Conflict of Interest Disclosure Statement?

Disclosures must be made whenever a new or altered Financial Interest develops and at the beginning of each fiscal year (July 1), thereafter.

Q 9. Where do I find the Conflict of Interest Disclosure Statement?

The form is available here.

Q 10. Where do I send my completed Conflict of Interest Disclosure Statement?

Completed forms should be sent to the Office of the Vice President for Ethics and Compliance in Young Hall on the West Lafayette campus.

Q 11. I submitted a Conflict of Interest Disclosure Statement; when can I expect to receive a response?

The COI Officer will review all forms and respond in a timely manner.

• If your disclosure was not necessary (i.e., there is no Conflict of Interest), your form will be returned to you.
• If a Financial Conflict of Interest is identified, you will be notified and the COI Officer will determine whether the conflict can be managed or needs to be eliminated.

Q 12. What happens if the COI Officer determines that there is a Financial Conflict of Interest?

If the conflict can be managed, the COI Officer will work with you to develop a written conflict management plan. If the conflict cannot or should not be managed, steps will need to be taken to eliminate the conflict. Examples of this include stopping the transaction that is the subject of the conflict or changing the role and/or responsibilities of the employee.

Q 13. I completed a Conflict of Interest Disclosure Statement last year. Why do I have to complete one again this year?

Indiana state statute requires annual reporting of Financial Interests relative to the University’s business, research and decisions.

Q 14. I completed a Conflict of Interest Disclosure Statement at the beginning of the year and now I’m going to be the director for a new sponsored project. Do I have to submit another form?

You will be required to complete a Research Related Significant Financial Interest Disclosure Form if you answered “yes” on your SFI Statement for the proposal. The form can be found on the Conflict of Interest page of the Office of the Vice President for Research website.

Q 15. If I don’t file a Conflict of Interest Disclosure Statement, what are the consequences?

You may be subject to any or all of the following.

• Discipline for misconduct and/or insubordination by the University.
• Charged with a Class D felony by the state of Indiana.
• If you are an Investigator on a sponsored project, any further sanctions issued by the granting agency.

Q 16. What if I am not satisfied with the decision regarding the existence of a Financial Conflict of Interest or the terms of a conflict management plan?

You may submit a written appeal to the COI Officer. The COI Officer will submit the appeal to the Conflicts Committee for review, whose decision on the matter is final.

Q 17. Does this policy prevent me from having my own business?

No. Depending on the type of business you have, there are some things to be aware of, such as:

• If your business does business with the University, you must file a Conflict of Interest Form for review prior to signing any contracts with the University or providing any goods or services.
• If you are an Investigator, you may be required to disclose your income from the business if it meets the definition of a Significant Financial Interest.
• You may not use any of the University’s facilities, personnel, equipment, IT Resources, confidential information or other resources for the purposes of your outside business.
• You are required to file a Reportable Outside Activity Form in accordance with the policy on Conflicts of Commitment and Reportable Outside Activities.

Q 18. I am a named beneficiary of a gift in support of my work at the University. Is there anything I need to do to comply with this policy?

Purdue’s policy on Gift Acceptance outlines procedures for determining whether any business or pecuniary ties exist between a donor and the recipient. In the event any such ties are identified, the COI Officer will work to create a satisfactory management plan.

Q 19. I have an invention that will be licensed through OTC. Does this policy require me to do anything?

If you have any Equity Interest, serve as an officer for or are involved in a management role for the third party to which OTC is considering licensing the invention, the Responsible Official will review the situation to determine whether a conflict management plan is needed. If a management plan is needed, the Responsible Official will work with you to develop one.

Q 20. When completing a Research Related Significant Financial Interest Disclosure Form, does a significant financial interest include remuneration from a nonprofit organization?

Yes, this should be included in your Research Related Significant Financial Interest Form.