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Conflict of Interest

Conflict of Interest


A conflict of interest arises when an individual's private interests (such as outside professional or financial relationships) might interfere with his or her professional obligations to Stanford. Such situations do NOT imply wrong-doing or inappropriate activities. However, in a research university setting, they can compromise, or be perceived as compromising, important academic values, research integrity, or the university mission. At Stanford, it is essential for all faculty, academic staff, staff, and students to understand how these divergent interests can become a problem.

Conflicts of interest often arise at the intersection of two fundamental missions: to push the boundaries of knowledge and to transfer that knowledge to the private sector for the benefit of the public. There may be, for example, significant personal financial incentives related to patenting and licensing an invention, or to outside consulting or other interests. Considerations of personal financial gain however must not influence the decisions or actions of individuals in carrying out their University responsibilities. The perception that such incentives might harm research objectivity, or the protection of human subjects, students or others whose work depends on the direction of the individual is enough to mandate that such conflicts be identified, and then managed, mitigated or eliminated.

Stated another way, Stanford University must protect itself and its faculty, staff and students from any of the following allegations:

· exploitation of students for private gain

· undue personal gain from public funds

· compromise of university priorities due to financial considerations

· unfair access by a company to information or technology

· compromise of scientific objectivity in the conduct of research

· compromise of appropriate controls in the conduct of research such that research subjects could be harmed

· use of university resources for private gain

· adverse effect by those in leadership roles on the professional or academic advancement of colleagues, staff or students as a result of outside interests.

To protect against such dangers, all faculty members must certify annually to their school deans their compliance with Stanford's policies related to conflict of interest and commitment, and must disclose their outside professional activities and any financial interests in outside entities that they, and their immediate family members, have. In addition, faculty, staff, postdocs and students must disclose on an ad hoc basis any current or prospective situations which may raise questions of conflict of interest, such as those involving sponsored research, gifts, human subject protocols, licensing of intellectual property, procurement or other relationships with outside companies. Ad hoc disclosures are to be made as soon as such situations become known to the individual.

Potential conflicts of interest will be assessed against the concerns listed above. Where there is a risk that the outside interest may have, or be perceived to have, a harmful affect on academic values, Stanford will take steps to eliminate, mitigate or manage the conflict.

The rest of this page will introduce you to Stanford's policies, and to other resources including case discussions, related to this important topic.

Questions?

If you have questions about any of this material, you may send an e-mail message to Stanford's Assistant Dean of Research and Graduate Policy. In the School of Medicine, contact Barbara Flynn.

Stanford Policies

             Stanford policies related to conflict of interest include:

Faculty Policy on Conflict of Commitment and Interest

Presents and discusses circumstances which can create real or perceived conflicts of commitment and conflicts of interest for faculty. Establishes the requirement for annual certification and financial disclosure.

PHS and NSF Requirements Regarding Financial Disclosures and Agency Notifications

Addresses the requirements of these two federal agencies related to financial disclosures by faculty members submitting proposals and notifications to agencies in the event a potential conflict is identified.

Conflict of Commitment and Interest for Academic Staff

Applies the principles of the Faculty Policy to members of the Academic Staff with two principal differences: consulting privileges are not normally extended to members of the Academic Staff, and Academic Staff are not normally required to complete an annual certification and disclosure.

Staff Policy on Conflict of Commitment and Interest [pdf file]

Establishes specific prohibitions and defines a process for disclosures of potential conflict situations.

Relationships Between Students (including Postdoctoral Scholars) and Outside Entities

Discusses the application of University policy related to intellectual property, openness in research and conflict of commitment and interest to students working with outside companies.

Related forms and disclosure information:

Annual Certification of Compliance to the Faculty Policy on Conflict of Commitment and Interest [Stanford access only]

Faculty may use this electronic application to submit their annual certifications and disclosures as required by the policy on this Stanford-access website. The site also contains information about the certification and disclosure process.

Attachment to Sponsored Projects Proposal Routing Sheet (SU-42) for Proposals to PHS, including NIH, or to NSF

Must be attached to the proposal routing sheet for any proposal going to either agency.

Guide To Ad Hoc Conflict of Interest Disclosures - General

Includes a template for disclosures whenever a current or prospective relationship creates the potential for conflicts of interest.

Ad Hoc Faculty Disclosures of Conflict of Interest at the School of Medicine

Federal Policies/Association Guidelines

Conflict of Interest Information Resources Available on the Web
Maintained by the National Institutes of Health (NIH)

Discussion of Cases

Conflicts of interest are sometimes difficult to consider in the abstract. The following three hypothetical situations illustrate potential conflicts involving:

· clinical research

· technology licensing agreements

· the direction of students/trainees

The analysis presented in these cases does not lead to simple answers. Rather, these cases are intended to point out the complexity involved in potential conflicts of interest, and to suggest questions to ask and possible approaches to consider.

Other Resources and Readings

· Stanford Report articles

· Experts explore ways of protecting patients when conflicts of interest arise August 8, 2001

· Preserving academic integrity in the face of increasing private investment June 13, 2001

· Research conflict-of-interest policies under scrutiny February 21, 2001

· On Being a Scientist A publication of the National Academy of Sciences

· Conflict of Interest - Moving Beyond Disclosure Science Magazine, Volume 291, Number 5506, Issue of 9 Feb 2001, p. 989. [Stanford access only]

· NIH Final Rule on Conflict of Interest, July 14, 1995

· NSF Investigator Financial Disclosure Policy, October 7, 1996

Frequently Asked Questions Concerning the Department of Health and Human Services (DHHS) Objectivity in Research Regulations and the National Science Foundation (NSF) Investigator Financial Disclosure Policies.


To contact us:
Roosmery Yang - NIH Grant Administrator
Department of Chemical Engineering
Stauffer III, Mail Code 5025
Stanford University
Stanford, CA 94305-5025
Tel: (650) 736-1807
Fax: (650) 725-7294
rwyang@stanford.edu

Link to Stanford University's Site

Professor James Swartz - Project DIrector
Department of Chemical Engineering
Stauffer III, Mail Code 5025
Stanford University
Stanford, CA 94305-5025
Tel: (650) 723-5398
Fax: (650) 725-7294
jswartz@stanford.edu