FINANCIAL CONFLICT OF INTEREST (FCOI) POLICY
CONFLICT OF INTEREST REPORTING PROCESS:
Princeton University is dedicated to the advancement, preservation and dissemination of knowledge; instruction of undergraduate, graduate and postdoctoral students; advancement of the public interest; and public welfare. Thus, teaching and research activities remain a primary responsibility at the University. Outside professional, financial and entrepreneurial activities of individual faculty and staff are welcomed and encouraged and contribute to the University’s mission by providing valuable public (and personal) benefits. First priority must, however, be devoted to one’s primary responsibilities and therefore Princeton University requires conflict of interest disclosures for all Dean of the Faculty (DOF) appointees, which includes all funded Faculty, Academic Professionals and Professional Librarians (in rare cases for externally funded grants, this may also include students, external consultants and collaborators) and non-funded DOF appointees that are >50% duty time. External interests and activities that have the potential to interfere with University responsibilities must be disclosed so as to minimize any risk of conflict with University objectives and values. These disclosed activities prevent any public perception of personal enrichment, so as to ensure that outside financial interests do not pose undue influence on teaching or research.
At the beginning of every calendar year (mid-January) all DOF appointees will be contacted via email from the DOF to complete and submit a Conflict of Interest Annual Disclosure Form found on the electronic Conflict of Interest Reporting System. The form requires an individual to disclose various potential conflicts in the following areas:
- Work for Outside Organizations (potential Conflicts of Commitment (COC))
- Management and Fiduciary Responsibility
- Nepotism and Personal Relationships
- Purchasing and Contracts
- Gifts and Solicitations
- Use of Resources including Students, Staff, Equipment or Space (potential Conflicts of Resources (COR))
- Significant Financial Interests (SFI) Relating to One’s Research or Teaching Activities that may present a potential Financial Conflicts of Interest (FCOI)
In addition, PHS-funded researchers must also disclose reimbursed or sponsored travel and any newly acquired SFI within 30 days of acquisition of either the travel or the SFI, if the amount meets the threshold (additional information below, including SFI thresholds). All Non-PHS funded DOF appointees and all other Faculty, Academic Professionals and Professional Librarians must also disclose any newly acquired SFI within 30 days of acquisition, if the amount meets the threshold (additional information below, including SFI thresholds). New SFIs that are acquired throughout the year should be disclosed using the Conflict of Interest update form which can be found via the electronic Conflict of Interest Reporting System.
Once the form is submitted, Research Integrity and Assurance (RIA) performs an initial review of all forms and routes any potential conflicts to the appropriate office for review and possible final determination. RIA may reach out to any individual that discloses an SFI (defined below) to ask clarifying questions or set up a meeting to discuss potential conflicts. Additionally the DOF, Dean of the Graduate School, Finance and Treasury, or Dean of the College may contact any individual if further clarifying information is required.
Once all the information is gathered, RIA may make a recommendation to the DFR as to whether a financial or other conflict of interest exists. If so, a management plan is put into place. If the conflicts are more complicated, RIA or the DFR may request that the conflict be reviewed by the Panel. The Panel meets twice a year (approximately in June and December) to discuss potential conflicts that are disclosed via the process identified above. Each identified potential conflict (COC, COR, and FCOI) is presented to the Panel and an action plan is developed to mitigate or eliminate any possible conflict(s).