Conflict of Interest Policy for East Central University

Please read the information below to find out more about Conflict of Interest Policy.

  1. At the time of submission of any grant or contract proposal to any federal agencies and department, each ECU faculty or staff member listed on the proposal as an investigator must submit to the Director of the Office of Sponsored Programs and Research a written statement divulging any significant financial interests of the investigator (including those of the investigator's spouse and dependent children) (i) that would reasonably appear to be directly and significantly affected by the research or educational activity funded or proposed for funding by the federal agencies or department; or (ii) any entities whose financial interests would reasonably appear to be directly and significantly affected by such activities.

    The term "significant financial interest" means anything of monetary value, including, but not limited to, salary or other payment for services (e.g., consulting fees or honoraria); equity interests (e.g.; stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights). The term does not include salary, royalties or other remuneration from the institution or any ownership interests in the institution, if the institution is an applicant under the Small Business Innovation Research Program or Small Business Technology Transfer Program; income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities; income from service on advisory committees or review panels for public or nonprofit entities; or financial interests in business enterprises or entities if the value of such interests does not exceed $5,000 or represent more than 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's spouse and dependent children.
  2. The Director of the Office of Sponsored Programs and Research will be responsible for reviewing any financial disclosure statements to determine whether an actual or potential conflict of interest exists. He will determine after consultation with the University President or his designee what conditions or restrictions, if any, should be imposed by the institution to manage, reduce or eliminate such conflicts of interest.
  3. Investigators must provide the required financial disclosure statements at the time of submission of the grant proposal. Further, any changes to the financial status pertinent to the proposal must be updated, if necessary, during the dependency of the award, either on an annual basis, or as new reportable significant financial interests are obtained.
  4. Any faculty member found to be in willful violation of this policy will be subject to normal university sanctions as detailed in the Personnel Policies of the university.
  5. The federal agencies and department will be notified in writing of any conflicts of interest not satisfactorily managed by the university. Such notification will be provided by the Director of the Office of Sponsored Programs and Research to the appropriate NSF program head within 30 days of any determination of potential conflict not agreeably managed by the university as determined by the University President or his designee.
  6. Financial Disclosure records will be kept by the university for a minimum of three years following the termination or completion of the award to which they relate, or the resolution of any government action involving those records.