The annual disclosure form includes questions that identify relationships that might affect your work for Princeton. Examples of areas that might be affected include how much time you spend working outside of the University (commitment). Another example is your ability to influence purchasing or recommending items for purchase on Princeton’s behalf. While many faculty and staff do not have all of these duties, most have at least one. The disclosure form requires providing information related to the following areas:

Whether you or a family member have a significant financial interest (SFI - explained below in Disclosures) that is related to, or overlaps with, your institutional responsibilities on behalf of Princeton or with a company that does business with Princeton;

Whether you or a family member serve on an outside entity’s board as a director, trustee, advisor, etc., or have a position with fiduciary obligations, including as a president, vice-president, treasurer, secretary, or other officer position;

Whether you are listed as an owner, inventor, contributor, or co-owner on any licensed or optioned intellectual property, including patents, provisional patents, copyrights, or trademarks;

Whether you are involved in any research that assesses a company's product, service, or intellectual property (e.g., something that could evolve into a product or new use for an existing product - whether or not you have any other relationship with the company or its competitors);

Whether you provide any advice to investors, including a hedge fund, venture capital firm, brokerage house, investment advisor, hedge fund manager, etc.;

Whether you have funding from an SBIR or STTR , i.e., types of federal awards provided directly to small businesses;

Whether any intermediary company receives money on your behalf, e.g., a consulting group that receives payment for your work (in which case you will be asked to identify the original funding entity);

Whether you employ or supervise a member of your family; and

Whether you engaged in government relations activities that Princeton must account for and report as lobbying activities to comply with federal (e.g., IRS) and state law.

A conflict of commitment exists when a non-Princeton obligation prevents an individual from spending the time required for his/her full-time commitment to the University.  Some examples include:

• Membership by an individual on multiple scientific advisory or corporate boards, including committees, that could take that individual away from his/her job at the University to the extent that the employee's full-time job obligations to the University are not met;
• Employment by another entity that is intended to be part-time, but that interferes with full-time duties at the University even if unrelated to the missions of Princeton (i.e., owner/manager in a start-up company); and
• For faculty, the fundamental rule is that consulting should be limited to 1 day per week (a maximum of 36 days/year for full-time employees).

Payments from an outside entity (i.e. a pharmaceutical company, a foreign university etc.) or anything of actual or potential monetary value owned by the employee or family member can be a significant financial interest if it meets the required thresholds and is related to one’s institutional responsibilities. 

Significant financial interest thresholds include:

• Any current or pending ownership interest in a privately held entity;
• Any current or pending ownership interest of >$5,000 or more in a publicly traded  entity that is related to their research or teaching activities;
• Any income amounting to >$5,000 per year per company/organization that is related to their research or teaching activities;
• Payments >$5,000 for services, including honoraria, consulting fees, lecture payments, etc. that are not otherwise excluded under the Policy (i.e. if it comes from a U.S. University, medical school, etc., See A9 below);
• A right of ownership in intellectual property (copyright, patent, trademark);
• Equity ownership (stock, stock option, security, or other ownership interest).

Princeton University only has to report these financial interests when they are related to the employee’s institutional responsibilities.   Institutional responsibilities include activities like research, teaching, and administrative activities (like purchasing).  We exclude hobbies or professional activities that do not relate to your work at Princeton.   For example, if an English professor was also a professional antique automobile appraiser, the appraising would not be related to her role as an English professor.

The following do not constitute financial interests of concern to this policy; therefore; do not need to be reported:

• Ownership of a share or shares in a mutual fund or retirement accounts that the individual does not directly control;
• Salary or other payment from Princeton University or another U.S. institute of higher education, from hospitals and medical centers, from research institutes, or from a branch of government, including federal, state, or local;
• Unlicensed intellectual property that does not generate income.

An FCOI exists when there is an SFI that has the potential to directly and significantly affect the design, conduct or reporting of funded research, or the performance of duties and responsibilities on behalf of Princeton. Some examples include:

• An SFI that affects the investigator’s objectivity such that the design, conduct, and reporting of research performed is not free from bias;
• An SFI that affects the purchase of items like equipment, supplies, and services.  For example, ownership by an administrator or a family member in a vendor or potential vendor that does or may do business with the University when the administrator has some control over the decision or recommendation of purchases from vendors offering the same services or products; and
• An SFI that affects what information the individual decides to include in an article or presentation.

The following factors are considered when determining whether an SFI should be considered an FCOI:

• Whether the research is of a basic or fundamental nature directed at understanding basic scientific processes
• Whether the degree of replication and verification of research results is such that immediate commercialization is not likely.
• Whether the research could have a significant impact on a company’s business or financial outlook.
• Whether one of the goals of the research is to validate or invalidate a particular approach or methodology that could affect the value of the SFI in the company.
• Whether the goal of the research is to evaluate an invention linked to the SFI (such as where the SFI is a patent, or an interest in a company that has licensed the invention)
• W here the SFI is in a privately held company that could result in the researcher having influence over company decisions, or whether the research could have a significant impact on the company’s business or financial outlook.  
• The number and nature of relationships the researcher has with an entity.   Multiple entanglements can create a relationship with an outside entity that is stronger than the sum of the parts.
• Whether other scientific groups are independently pursuing similar questions.  
• The magnitude of the SFI

For PHS funded (or foundations that the follow the PHS COI regulations) DOF appointees, there is a 30-day updating requirement when a new SFI is acquired. For example, if you are the PI on a research project funded by the NIH or CDC, then this requirement will apply to you. Likewise, if you are a co-investigator, independent investigator, key person or a mentor/sponsor on an NIH or CDC funded research project then this requirement will likely apply to you. Non-PHS funded and non-funded DOF appointees must disclose an SFI either on an annual basis or as new reportable financial interests are obtained.

If you are an “investigator” on a U.S. Public Health Service (i.e., NIH, FDA, CDC, etc.) funded award (see A1 above), you must disclose reimbursed or sponsored travel related to your institutional responsibilities over the previous twelve-month period to Princeton no later than the time of application for funded research. You must also submit an updated disclosure of reimbursed or sponsored travel within 30 days of each occurrence. 

Princeton University currently only requires reporting if PHS (or a component agency) is the sponsor. 

You can report the sponsored or reimbursed travel at the following link: Princeton Conflict of Interest in Reporting System

Sponsored travel is travel that is paid directly by the sponsoring entity and is not reimbursed to the investigator. For example, a professional organization in Italy pays directly for your flight and hotel expenses when you attend the organization’s conference as an invited speaker. In most cases, the exact value of the sponsored travel is not known to you as the traveler. However, for reporting purposes, you can make a good faith estimation as to the approximate value of the travel.

No, the PHS COI regulations allow institutions to set internal thresholds for reporting travel. At Princeton, the threshold has been set to $5,000 to align with the Significant Financial Interest threshold. Therefore, you only need to report travel that meets the following criteria:

• The aggregate value of the travel is greater than $5,000 from a single entity over a 12-month period; and
• The travel is related to your University institutional responsibilities and professional expertise.

Please note that if a company or organization sponsors or reimburses multiple small trips over the course of a year, each of which has a value of less than $5,000 but, when added up over a 12-month period exceed $5,000, then these trips have to be reported.

The $5,000 threshold does not mean that an investigator cannot have sponsored or reimbursed travel of more than $5,000. Rather, it means that any travel that exceeds this threshold must be reported.

This disclosure requirement does not apply to:

• Any travel reimbursed, sponsored or paid for by a U.S. government agency, a U.S. higher education institution, a U.S. academic teaching hospital, medical center, or a U.S. research institute affiliated with a U.S. higher education institution; and
• Any travel reimbursement or payment of travel made by Princeton University

As long as an individual was not making financial or personnel decisions relative to the University that involved another entity, it might be acceptable to take a gift, so long as it is not too extravagant.

If the individual was somehow involved with influencing University spending as it relates to potential spend with another entity, it would be unethical to accept this gift

When in doubt, don’t accept it.

Gifts that could be allowed include:

• Accepting a meal from a potential contributor or donor to Princeton, when development activities are part of the employee’s job responsibilities;

Accepting a gift from a current or potential vendor that is unrelated to the employee’s job responsibilities, e.g., for an existing personal relationship.