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Conflicts of Interest

Conflicts of Interest

Laws and Regulations

NOTE: These laws and regulations apply to all SUNY employees



SUNY Policies

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.

Policy on Conflicts of Interest in Public Health Service Sponsored Programs, Document Number 1000
This Policy provides for the disclosure, management and reporting of financial conflicts of interest of investigators who apply for, receive or participate in research sponsored by the Public Health Service of the U.S. Department of Health and Human Services and its component agencies, including the National Institutes of Health.

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.

START-UP NY Program Participation Policy
Section D of the START-UP NY Policy is a Conflicts of Interest provision.  It states the following:

Conflicts of Interest: Service as an Official shall not be used as a means for private benefit or inurement for any Official, a Relative thereof, or any entity in which the Official or Relative thereof has a Business Interest. A conflict of interest exists whenever an Official has a Business Interest or other interest or activity outside of the university that has the possibility, whether potential, actual, or perceived, of (a) compromising the Official's judgment, (b) influencing the Official's decision or behavior with respect to the START-UP NY Program, or (c) resulting in personal or a Relative's gain or advancement. Any Official who is an owner or employee of an entity that is the subject of any matter pertaining to the university's START-UP NY Program, or who has a Business Interest in any entity that is the subject of any matter pertaining to the university's START-UP NY Program, or whose Relative has such a Business Interest, shall not vote on or otherwise participate in the administration by the university of any START-UP NY matter involving such entity. Any Official or other campus representative who becomes aware of a potential, actual or apparent conflict of interest, either their own or that of another Official, related to a sponsoring university or college's START-UP NY program must disclose that interest to the President or Chief Executive Officer of the sponsoring college or university. Each such President or Chief Executive Officer shall maintain a written record of all disclosures of actual or potential conflicts of interest made pursuant to this policy, and shall report such disclosures on a calendar year basis, by January 31st of each year, to the University Auditor or to the Chancellor's designee, in which case the University Auditor shall be copied on the correspondence to such designee. SUNY shall then forward such reports to the Commissioner of Economic Development for the State of New York, who shall make public such reports.

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.

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.

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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. For legal advice, consult your lawyer.