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Financial Conflict of Interest for Externally Sponsored Projects
Santa Clara University is committed to promoting objectivity in teaching and research. Any Santa Clara University faculty or staff member who is funded by or is responsible for the design, conduct, reporting or approval of any externally sponsored project is required to disclose all known significant financial interests and those of his or her family members (spouse and dependent children) that would reasonably appear to be affected by the project. The detailed policy is listed below and is available to download on the right. Detailed procedures are also available along with FAQs prepared by the National Institutes of Health.
General Disclosure Procedures:
When submitting a proposal to an external sponsor, a faculty or staff member must submit a completed Disclosure form to the Sponsored Projects Office. An update using the same form is required if a full form has been completed in the past three years.
When a grant is received, all faculty and staff working on the project must complete a full Disclosure form if a form has not been completed in the past three years and submit an annual update to the Disclosure form.
Santa Clara University is committed to promoting objectivity in teaching and research. The purpose of this policy is to ensure there is no reasonable expectation that the design, conduct, or reporting of research or other projects funded by external sponsors will be biased by any conflicting financial interest. The policy establishes a written and enforced administrative process to identify and to manage, reduce or eliminate conflicting interests with respect to all externally sponsored projects. The policy also supports Santa Clara University’s institutional compliance with the Public Health Service regulations (42 CFR Part 50, Subpart F ) and the provisions of the National Science Foundation (Grant Policy Manual § 150 ).
The policy applies to all Santa Clara University faculty and staff who are funded by or are responsible for the design, conduct, reporting or approval of any externally sponsored project at Santa Clara University.
The policy also applies to subgrantees, contractors, or collaborators of Santa Clara University involved in an externally sponsored project unless individuals can provide written assurance to the Director of Sponsored Projects that they are subject to a similar financial conflict of interest policy.
Any Santa Clara University faculty or staff member who is funded by or is responsible for the design, conduct, reporting or approval of any externally sponsored project is required to disclose all known Significant Financial Interests and those of his or her family members that would reasonably appear to be affected by the project.
Enforcement and Noncompliance
The Senior Associate Provost for Research and Faculty Affairs and Director of Sponsored Projects are responsible for enforcement of the policy. Examples of noncompliance with this policy include, but are not limited to, failure to submit a disclosure form, intentionally filing an incomplete, erroneous, or misleading disclosure form, or failing to provide any additional information requested by the Director of Sponsored Projects or the Senior Associate Provost for Research and Faculty Affairs. Failure to comply with this policy will result in the notification of the sponsor (Procedure Section G) and immediate suspension of all sponsored project funds. In addition, noncompliance may result in disciplinary action consistent with and subject to sections of the Staff Policy Manual and the Faculty Handbook that are applicable to the employment of the faculty or staff member. In particular, noncompliance is subject to the Policy on Misconduct in Research (Faculty Handbook, Appendix H).
Financial Conflict of Interest exists when significant financial interest may affect the design, conduct, or reporting of the externally sponsored project. This includes situations where financial considerations may compromise or have the appearance of compromising faculty or staff member’s professional judgment in conducting or reporting research, impacting the collection, analysis, and interpretation of data, hiring of staff, procurement of materials, sharing of results, choice of protocol, involvement of human subjects and application of statistical methods.
Family Member means the faculty or staff member’s spouse or dependent children.
Research means a systematic investigation designed to develop or contribute to knowledge. The term encompasses basic and applied research and product development.
Significant Financial Interest 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); and intellectual property rights (e.g., patents, copyrights and royalties from such rights). Examples of Significant Financial Interest might include employment of a spouse by the potential sponsor or a consulting arrangement with a company that might benefit financially from the sponsored project. Other examples are listed in Appendix A.The term does not include:
(1) salary, royalties, or other remuneration from Santa Clara University;
(2) income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
(3) income from service on advisory committees or review panels for public or nonprofit entities;
(4) an equity interest that when aggregated for the faculty or staff member and his or her family members meets both of the following tests:
(5) salary, royalties or other payments that are not from Santa Clara University and that when aggregated for the faculty or staff member and his or her family members over the next twelve months, are not expected to exceed $5,000.
Sponsored Project means any externally funded activity which is subject to an agreement that is binding on the University and that includes any of the following conditions:
Examples of Significant Financial Interests
The following are examples of Significant Financial Interests that must be reported on the Statement of Significant Financial Interests Form. These examples are neither exclusive nor exhaustive of the types of significant financial interests that may be reportable under the Policy on Financial Conflict of Interest for Externally Sponsored Projects.