Disclosure and Management
It is the responsibility of every covered employee, as defined by the COIC Policy, to disclose conflicts of interest and commitment, whether or not the employee thinks the situation requires management and whether or not a management plan is already in place. Employees shall disclose electronically via IRBManager at the beginning of employment and thereafter annually beginning January 1 (with a target completion of March 31), and whenever the employee’s situation changes.
Why Manage Conflicts of Interest and Commitment?
Conflicts of interest and commitment, if not properly managed, can hurt the employee, the university, the state, and the public in general. Below are examples of some of the undesirable outcomes of the failure to disclose and/or adequately manage conflicts of interest and commitment. The examples are not all inclusive.
- The use or the perception of use of state resources for personal benefit or the benefit of immediate family members. This may occur when, for example:
- A person's business or business activities share space or equipment with or are in close proximity to a person's departmental or center facilities.
- A person gives/receives an ISU grant, contract, subcontract or purchase order to/from a family member's company, whether for-profit or not-for-profit.
- A person gives/receives (or appears to give/receive) an ISU grant, contract, subcontract or purchase order to/from theirself.
- The use or perception of use of the employee's university position to influence university business in a way that benefits one's self or immediate family members. This may occur when, for example:
- A person's (or immediate family member's) business creates a widget, a computer program, or other item of value that the university wants and the person is in a position to influence the decision to purchase the item.
- A person is in a position to decide who will be the recipient of a grant, contract, subcontract, or purchase order and one of the possibilities is that person or an immediate family member.
- Confusion in the ownership of intellectual property. This may occur when, for example:
- A person's business's research activities are closely related conceptually to their university research activities.
- A person's business activities share space, equipment or personnel with their university activities.
- A person signs a consulting contract with a company and the contract specifies that all information provided by the consultant belongs to the company.
- Questions about the integrity of an employee's university research. This may occur when, for example:
- A person, the person's family, or close associates stand to gain financially depending on the outcomes of the person's university research.
- A university stands to gain financially depending on the outcome of university research.
- Harm to vulnerable populations, such as graduate students and research subjects. This may occur when, for example:
- A graduate student conducts their masters or doctoral research in the major professor's company.
- A researcher stands to profit financially depending on the results of their clinical research.
- A researcher consults for a company that sponsors their clinical research.
ISU policy and federal regulations require the development of written Conflict of Interest Management Plans whenever real or perceived conflicts of interest are identified. Because all conflict of interest situations are unique, the content of these plans varies. Conflict of Interest Management Plans are developed by a Conflict of Interest Management Committee in consultation with the persons involved. The plans must be reviewed and renewed yearly as long as the person is an ISU employee and the conflict of interest situation exists.