Conflicts of Interest and Commitment
In academic research, the term "conflicts of interest" refers especially to situations in which financial or other personal considerations may compromise, or may have the appearance of compromising, an investigator's professional judgment in designing, conducting or reporting research. The bias could affect collection, analysis, and interpretation of data, hiring of staff, procurement of materials, sharing of results, choice of protocol, and the use of statistical methods.
Conflicts of commitment are situations in which external activities, either paid or unpaid, interfere with an employee's primary obligation and commitment to the Institute.
To protect against actual conflicts of interest and commitment and to guard against public perception of conflicts, every Caltech researcher must disclose, through the "Disclosure of Financial Interests and Commitments," professional activities outside of Caltech and any financial interests in outside entities that the researcher, and his/her immediate family members may have that are related to the researcher's institutional responsibilities. As part of the disclosure process, each researcher must certify that he/she is in compliance with all applicable Caltech policies and procedures. Disclosures must be made at least annually; however researchers are required to disclose, on an ad hoc basis, any current or prospective situations which may raise questions of conflict of interest or commitment. Examples of such potential conflict situations are situations that arise when a researcher has an interest in, is a board member or is consulting for a company that is sponsoring research, donating gifts, collaborating on human subject protocols, licensing Caltech intellectual property, or is a subawardee or subcontractor. Ad hoc disclosures are also made through the "Disclosure of Financial Interests and Commitments," as the individual becomes aware of such situations. The appropriate Division Chair or Supervisor will review all disclosures to determine if an actual or apparent conflict exists and will work with the researcher to manage any conflict situations.
As of August 24, 2012, Caltech's Conflicts of Interest Policy has an addendum applicable to all researchers who are responsible for the design, conduct or reporting of research and who receive federal funding for their research, particularly NIH and NSF funding. The addendum is Caltech's Policy for Managing Conflict of Interest Requirements Imposed by Federal Sponsors. There are also new procedures implementing the policy. Caltech's electronic "Disclosure of Financial Interests and Commitments," access.caltech.edu has been updated to accommodate changes in the regulations. Additionally, Caltech researchers who are responsible for the design, conduct, or reporting of NIH funded research are required to take training. Caltech PHS NIH COI Training and quiz is available through your access.caltech.edu account as well. If you do not see the training under your "Training and Professional Development" after signing into access.caltech.edu, please contact the Office of Research Compliance to enroll. If you have any questions regarding the regulations, please feel free to contact the Office of Research Compliance at firstname.lastname@example.org.