Federal Requirements for Conflicts of Commitment and Interest (S-34)

Standard: S-34
Responsible Executive: Vice President for Ethics and Compliance
Responsible Office: Offices of the Vice President for Ethics and Compliance and the Executive Vice President for Research
Date Issued: August 17, 2026
Date Last Revised: N/A

Table of Contents

Contacts
Individuals and Entities Affected
Statement of Standard
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
History and Updates
Appendix

Contacts

Clarification of Standard

Vice President for Ethics and Compliance
765-494-5830 | vpec@purdue.edu 

Questions on Conflicts of Commitments

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

Questions on Conflicts of Interest

Executive Vice President for Research
765-494-6840 | fcoi@purdue.edu | EVPR’s Research Related COI website

Individuals and Entities Affected

All individuals designated as a Covered Individual, and all units of the University involved in requiring, receiving, reviewing, or taking action on disclosures pertaining to Conflicts of Commitment or Conflicts of Interest.

Statement of Standard

Purdue University is an applicant and recipient of federal financial assistance, including from the U.S. Department of Energy (DOE). As such, Purdue must address actual, apparent and potential Conflicts of Interest and Conflicts of Commitment, both foreign and domestic as required by federal regulations.

This standard supplements the policies on Conflicts of Commitment and Reportable Outside Activities (III.B.1) and Individual Financial Conflicts of Interest (III.B.2)  by identifying the requirements for Covered Individuals, which vary slightly from the requirements in the aforementioned policies.

Covered Individuals must make disclosures as outlined in the Responsibilities section. A Covered Individual who fails to make disclosures required by this standard, or who otherwise violates any of the provisions in this standard or in a management plan, may be subject to appropriate sanctions, including but not limited to, discipline for misconduct and/or insubordination under University policies, practices, and procedures, up to and including termination of employment.

Responsibilities

Covered Individuals

• Provide all required disclosures no later than the time an application is submitted to the DOE. If added after the time of application, make such disclosures prior to participating in a project funded under a DOE federal financial assistance award.
• Disclose reimbursed or sponsored travel, including the purpose of the trip, the identity of the sponsor/organizer, the destination, and duration. Provide additional information requested by the Responsible Official. 
• Update disclosures on an annual basis and as soon as practicable, but not later than 15 days after any new actual, apparent, or potential Conflict of Interest (COI) or Conflict of Commitment (COC) arises.
• Sign and date each disclosure and include the required certification.
• Complete COI and COC training prior to engaging in projects funded under a DOE federal financial assistance award and complete refresher training at least every two years.
• Complete COI and COC training within 30 days of any of the following circumstances:
  • Revision of this standard that affects the responsibilities of a Covered Individual;
  • The Covered Individual is new to Purdue; or
  • A finding of non-compliance with this standard or applicable management plan.

Responsible Official

• Review COI and COC disclosures from each Covered Individual who is planning to participate in, or is participating in, a project funded under a DOE federal financial assistance award.
• Review all Covered Individuals’ disclosures to determine whether an actual, apparent, or potential COI or COC exists; and, if so, determine the actions that have been and will be taken to eliminate or, where appropriate, manage or reduce the conflict.
• In the case of a disclosure of reimbursed or sponsored travel, determine whether the travel constitutes a COI or COC with the project funded by the DOE federal financial assistance award.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms. Similar terms may be used in this standard’s related policies; however, the definitions provided below are specific to this standard, unless otherwise noted.

Conflict of Commitment (COC)
A situation in which an individual accepts or incurs conflicting obligations, whether foreign or domestic, between or among multiple employers or other entities. This may include conflicting commitments of time and effort, including obligations to dedicate time in excess of institutional or DOE policies or commitments. Other types of conflicting obligations include, but are not limited to, obligations to improperly share information with, or to withhold information from, an employer or the DOE, can also threaten research, technology or economic security and integrity.

Examples of situations that may give rise to Conflicts of Commitment include, but are not limited to, current or pending employment; positions, appointments, or affiliations such as titled academic, professional, or institutional appointments, whether remuneration is received and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary positions); participation in or applications to Foreign Talent Recruitment Programs (FTRPs) or similar programs, and reimbursed or sponsored travel.

Conflict of Interest (COI)
A situation in which a Covered Individual or the spouse or a child of a Covered Individual has a Significant Financial Interest or financial relationship, whether with a domestic or foreign entity, that could directly and significantly affect the design, conduct, reporting or funding of a project or other federal financial assistance award-related activities.

Examples of situations that may give rise to a COI include, but are not limited to, holding an executive position, director position, or equity over a certain dollar amount in a company that stands to benefit from federal financial assistance award-related activities, receiving financial compensation in the form of consulting payments or payment for services from a company that stands to benefit from federal financial assistance award-related activities, or intellectual property rights or royalties from such rights whose value may be affected by the outcome of federal financial assistance award-related activities, and receiving reimbursed or sponsored travel.

Covered Individual
Any individual, regardless of title or position, who:

1. Contributes in a substantive, meaningful way to the development or execution of the scope of work of a project funded by the DOE or proposed for funding by the DOE; and
2. Is designated as a covered individual by the DOE.

The DOE designates as Covered Individuals any principal investigator (PI), project director (PD), co-principal investigator (Co-PI), co-project director (Co-PD), project manager, and any individual regardless of title that is functionally performing as a PI, PD, Co-PI, Co-PD, or project manager; and persons designated in the applicable Notice of Funding Opportunity (NOFO) or terms and conditions of the federal financial assistance award. Submission of a current and pending support disclosure and/or biosketch/resume for a particular person serves as an acknowledgement that the DOE designates that person as a Covered Individual.

Financial Interest
Anything of monetary value, whether or not the value is readily ascertainable.

Other Support
All resources made available to a Covered Individual in support of and/or related to all of their professional research (including basic and fundamental research), development, demonstration, and/or deployment efforts, including resources provided directly to the Covered Individual rather than through the research organization, and regardless of whether or not they have monetary value (even if the support received is only in-kind, such as office/laboratory space, equipment, supplies, or employees). This includes resources and/or financial support from all foreign and domestic entities, including, but not limited to, gifts provided with terms or conditions, gifts provided without terms or conditions, financial support for laboratory personnel, and participation of student and visiting researchers and visiting scholars supported by other sources of funding.

Responsible Official
See definition in the policy on Individual Financial Conflicts of Interest (III.B.2).

Significant Financial Interest

1. A financial interest consisting of one or more of the following interests of the Covered Individual (and those of the Covered Individual’s spouse and dependent children) that reasonably appears to be related to the Covered Individual’s non-federal entity responsibilities:
   1. With regard to any foreign or domestic publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000. For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;
   2. With regard to any foreign or domestic non-publicly traded entity, a significant financial interest exists if the value of any remuneration, not otherwise disclosed as current, pending, or other support, received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when the Covered Individual (or the Covered Individual’s spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); and
   3. Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and interests.
2. Any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Covered Individual and not reimbursed to the Covered Individual so that the exact monetary value may not be readily available) related to their institutional responsibilities that is not otherwise disclosed in current and pending or Other Support disclosures, but does not include travel that is reimbursed or sponsored by a federal, state, or local government agency of the United States; a domestic institution of higher education; or a domestic research institute that is affiliated with a domestic institution of higher education.
3. The term Significant Financial Interest does not include the following types of financial interests:
   1. Salary, royalties, or other remuneration paid by the non-federal entity to the Covered Individual if the Covered Individual is currently employed or otherwise appointed by the non-federal entity, including intellectual property rights assigned to the non-federal entity and agreements to share in royalties related to such rights;
   2. Any ownership interest in the non-federal entity held by the Covered Individual, if the non-federal entity is a commercial or for-profit organization;
   3. Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Covered Individual does not directly control the investment decisions made in these vehicles;
   4. Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency of the United States, a domestic institution of higher education, or a domestic research institute that is affiliated with a domestic institution of higher education; or
   5. Income from service on advisory committees or review panels for a federal, state, or local government agency of the United States, a domestic institution of higher education, or a domestic research institute that is affiliated with a domestic institution of higher education.

Related Documents, Forms and Tools

This standard is issued in support of the policies on Conflicts of Commitment and Reportable Outside Activities (III.B.1) and Individual Financial Conflicts of Interest (III.B.2), as amended or superseded.

Financial Assistance Regulations-Conflict of Interest and Conflict of Commitment Policy Requirements

History and Updates

August 17, 2026: Standard developed to address differences in certain federal financial assistance reporting regulations.

Appendix

There are no appendices to this standard.