Foundation and Corporate Relations

From the Faculty Handbook, Section 11.23

In accordance with federal regulations, Allegheny College has a responsibility to assess and manage any actual or potential conflicts of interest that may be presented by a grant applicant’s financial interest with the potential to harm the integrity of the proposed work or the reputation of the College. Faculty and staff of the College who propose to receive funds from an external source for research or academic projects must disclose—before applying for grants or contracts— any substantive financial interest that may reasonably appear to be affected by external funds. A possible conflict of interest does not preclude acceptance of external funding, but appropriate disclosures or other safeguards may need to be implemented and accepted by both the grant applicant and the institution. Information received on possible financial interests in a proposed project will be kept strictly confidential; however, records of such internal disclosure may be subject to IRS audit or court subpoenas.

Each faculty or staff member who proposes to receive a governmental or corporate grant or contract must complete and sign a form (at the time of application and annually for the duration of the award) that enables the College to assess the following three issues.

1. Does the applicant, his or her colleagues, family, or associates have a substantive financial interest or business relationship that would reasonably appear to be affected by the conduct or outcome of the grant-funded activities?

A substantive financial interest or business relationship means anything of monetary value, including, but not limited to

• salary or other payments for services (e.g., consulting fees or honoraria)
• equity interests (e.g., stocks, stock options or other ownership interests) not to exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a five percent ownership interest in any single entity
• intellectual property rights (e.g., patents, copyrights and royalties from such rights).

It does not include salary, royalties, or other remuneration from the College; income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; income from service on advisory committees or review panels for public or nonprofit entities; salary, royalties or other payments that when aggregated for the applicant’s household over the next twelve months, are not expected to exceed $10,000.

A conflict of interest would exist when a financial interest or business relationship could directly and substantively affect the design, conduct, or reporting of the proposed externally funded project.

2. Will the financial interest potentially affect the integrity of the project?

3. If a potential effect or the appearance of an effect on the project is present, what steps will the applicant and the College take to assure its integrity?

Conflict of Interest Disclosure Forms will be reviewed by the Office of the Dean of the College to determine whether a potential for conflict of interest exists.

If the Dean, in consultation with Legal Counsel, determines that there is a potential for conflict of interest covered by this policy, then the applicant should discuss with appropriate College officials proposed measures that will be taken to manage, reduce, or eliminate any actual or potential conflict of interest presented. After such discussions, the Dean will determine what conditions or restrictions, if any, should be imposed by the College in a resolution plan.

Conditions and restrictions may include public disclosure of significant financial interests; review of research protocol by independent reviewers; monitoring of research by independent reviewers; modification of the research plan; disqualification from participation in all or a portion of the research funded; divestiture of significant financial interests; or severance of relationships that create actual or potential conflicts.

A plan for reducing or eliminating conflicts of interest, detailing any conditions or restrictions imposed on the applicant, shall be agreed upon and signed by the applicant and the Dean of the College. All required reports regarding the conflict of interest will be submitted to the sponsor prior to expenditure of any funds under an award. Applicants are expected to comply fully and promptly with the policy. If the policy is found to have been violated, the Dean shall make recommendations to the President regarding the imposition of sanctions or disciplinary proceedings against the violating individual. The College will follow federal regulations regarding the notification of the sponsoring agency in the event of failure to comply with this policy. The sponsor may take its own action as it deems appropriate, including the suspension of funding until the matter is resolved.

Records of financial disclosures and of actions taken to manage actual or potential conflicts of interest, shall be retained by the Office of the Dean of the College until three years after the later of the termination or completion of the award to which they relate or the resolution of any government action involving those records.

September 2007