Research Compliance (including Human Subjects) Conflict of Interest Policy

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Conflicts of Interest

SUNY Policies: https://www.suny.edu/compliance/topics/research/conflictofinterest.cfm
SUNY Conflict of Interest Policy, Document Number 6001
Faculty and staff of the State University of New York (University) are encouraged to foster an atmosphere of academic freedom by promoting the open and timely exchange of scholarly knowledge independent of personal interests and are required to avoid conflicts of interest. Where potential or actual conflicts exist, faculty and staff are expected to consult with appropriate University officers and abide by University policy. This policy represents a restatement of existing University policy and pertinent state and federal law and regulations.

Research Foundation Conflict of Interest Statement

  1. Definition: As used in this section: the term Research Foundation shall mean The Research foundation of State University of New York. The terms "officer" and "employee" shall include any person representing or acting on behalf of the Research Foundation in any capacity in a program or project sponsored through the Research Foundation.

  2. The Rule With Respect to Conflicts of Interest: No officer or employee of the Research Foundation should have any interest, financial or otherwise, direct or indirect, or engage in any business or transaction or professional activity or incur any obligation of any nature, which is in substantial conflict with the proper discharge of his/her duties in the best interests of the Research Foundation.

  3. Standards:

    1. No officer or employee of the Research Foundation should accept other employment, which will impair his/her independence of judgment in the exercise of his/her duties and responsibilities.

    2. No officer or employee of the Research Foundation should accept employment or engage in any business or professional activity, which will require him/her to disclose confidential information, which he/she has gained by reason of his/her position or authority.

    3. No officer or employee of the Research Foundation should disclose confidential information acquired by him/her in the course of his/her duties except as required by law nor use such information to further his/her personal interests, unless such information has previously been made public.

    4. No officer or employee of the Research Foundation should use or attempt to use his/her position to secure privileges or exemptions for himself or herself or others.

    5. No officer or employee of the Research Foundation should engage in any transaction as representative or agent of the Research Foundation with any business entity in which he/she has a direct or indirect financial interest that might reasonably tend to conflict with the proper discharge of his/her duties or responsibilities.

    6. An officer or employee of the Research Foundation should not by his/her conduct give reasonable basis for the impression that any person can improperly influence him/her or unduly enjoy his/her favor in the performance of his/her duties, or that he/she is affected by the kinship rank, position or influence of any party or person.

    7. An officer or employee of the Research Foundation should abstain from making personal investments in enterprises which he/she has reason to believe may be directly involved in decisions to be made by him/her or which will other wise create conflict between his/her duties in the best interests of the Research Foundation and his/her private interest.

    8. An officer or employee of the Research Foundation should pursue a course of conduct which will not raise suspicion that he/she is likely to be engaged in acts that are in violation of his/her trust.

  4. Disclosure: All apparent conflicts of interest must be disclosed to the Campus President or his designee, or, for employees of the Albany Central Office of the Research Foundation, to the President of the Research Foundation, for review and determination of whether a violation of this statement exists. Any determination by the Campus President or his designee shall be forwarded to the President of the Foundation.

  5. Complaints or Inquiries: All complaints or inquiries concerning possible violation of this Conflict of Interest Statement should immediately be reported to the Campus President or his designee, or for employees of the Albany Central Office of the Research Foundation, to the President of the Research Foundation, for review and a determination as to whether a violation of this Statement exists. Any determination by the campus President or his designee shall be forwarded to the President of the Foundation.

  6. Violations: In addition to any penalty contained in any provision of law, any such officer or employee who knowingly and intentionally violates any of these provisions may be suspended from employment with the Foundation or his/her relationship with the Foundation terminated.

 
SUNY & Research Foundation Statement on Research Integrity
Adopted by Board Resolution in March of 2013, it is a university-wide statement containing 16 core principles on research integrity. The SUNY Statement on Research Integrity incorporates best practices advanced by the White House and around the world, and serves as an important reaffirmation of SUNY’s commitment to integrity in research.
 

References to Best Practices & Other Supplemental Material:

NIH/NSF Conflict of Interest - Research Conflict of Interest

National Council of University Research Administrators (NCURA) YouTube training video
This two-minute video provides a clear and concise overview of NIH/NSF Conflict of Interest Guidelines.

The Research Foundation of State University of New York (“RF”) DRAFT Model CAMPUS POLICY ON INSTITUTIONAL CONFLICTS OF INTEREST IN HUMAN SUBJECTS RESEARCH
This draft model policy was created in 2012 by the RF and is intended for campuses to use as a guide for their own human subjects Conflict of Interest Policies.

Financial Conflict of Interest Resources

Financial Conflict of Interest webpage, U.S. Department of Health and Human Services, Office of Extramural Research, National Institutes of Health.
The NIH is committed to preserving the public’s trust that the research supported by us is conducted without bias and with the highest scientific and ethical standards. We believe that strengthening the existing regulations on managing financial conflicts of interest is key to assuring the public that NIH and the institutions we support are taking a rigorous approach to managing the essential relationships between the government, federally-funded research institutions, and the private sector.

  • 2011 Regulation Revision 'FAQ' (Frequently Asked Questions)
    • FROM THE SITE: "The objectivity of research is of paramount importance and the basis for obtaining and maintaining public trust. To address the increasing complexities of the financial interests held by biomedical and behavioral researchers and the resulting interactions among Government, research Institutions, and the private sector, the Public Health Service (PHS) and the Office of the Secretary of the U.S. Department of Health and Human Services (HHS) published revised regulations .... [that] establish new standards and clarify previously established standards to be followed by Institutions that apply for or receive research funding from PHS Awarding Components, including the National Institutes of Health (NIH), for grants, cooperative agreements, and research contracts."
    • "The 2011 revised regulations were written to increase accountability, add transparency, enhance regulatory compliance and effective Institutional management of Investigators’ financial conflicts of interest, and strengthen NIH’s compliance oversight. The primary goal is to promote objectivity by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under PHS grants, cooperative agreements and contracts will be free from bias resulting from Investigator financial conflicts of interest."

The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements. The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses. Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete. For complete compliance information, consult your campus compliance officials or the SUNY Compliance Administrator. For legal advice, consult your lawyer.