Conflict of Interest

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As a place of learning, Simon Fraser University encourages its faculty, staff and students to be broadly involved in professional interests and activities compatible with the university’s mission, values and commitments. Occasionally, the best interests of the university and the personal interests of its members may conflict, or may be perceived to conflict.

To maintain public and professional trust and confidence, the university must deal with a real, potential, or perceived conflict of interest (COI) in a fair, open, consistent and practical way.

Disclosure

An undisclosed, unmanaged conflict of interest (whether real, potential or perceived) has the potential to create mistrust in the researcher, their colleagues and the institution. While not all conflicts of interest are avoidable, with full disclosure they can be managed before the research begins. Disclosure of COI is required by both institutional and federal Responsible Conduct of Research policies.

If you are in a situation where your personal interest is not clearly separated from your official institutional capacity (researcher, administrator, etc) – even if it only appears so - you must go through the disclosure and management process detailed in Policy GP37.

Identifying conflicts

COI exists where personal and work interests coincide. Even if a possible conflict has been mitigated (eg you have put an arms-length delegate in place to make a hiring decision), declaration is still necessary to avoid the perception of COI by outside observers. Some examples of possible COI situations:

• Do you serve on the board of a company from which you are seeking research funding?
• Do you wish to employ your well-qualified spouse or child to work on your research grant?
• Do you hold intellectual property interests in a tool or testing device that will be used in a funded study, in part to assess the effectiveness of that tool or device?
• Have you been reimbursed for travel or for a talk at a company that wishes to contract with SFU in support of your research?
• Do you take fees as a director of a company whose business lies in your area of academic expertise?  Does the company employ students that you supervise?

A perceived COI is as important to manage as an actual COI. It is vital to stop and view your activities from a different perspective. Even if the conflict is already well managed, the declaration is what protects you. Without the declaration you are violating both SFU and federal policy.

The disclosure process

Any member of the university (staff, faculty or student) completes a Conflict of Interest Disclosure Form after working with their supervisor (for faculty: Chair or ADR) to develop an appropriate management plan. For PIs and students, the approver/decision-maker is your Dean. For staff, it is your direct supervisor. For any COI that involves human-participants research, the approver is the Research Ethics Board via SFU Research Ethics.

The approver reviews the disclosure and determines whether a conflict of interest exists and whether it can be managed using the plan or must be disallowed.

Financial Conflict of Interest - US Funds

Each Investigator responsible for the design, conduct, or reporting of research supported by the US Public Health Service, including NIH, is required to disclose their Significant Financial Interests (and those of the Investigator’s spouse and dependent children) that reasonably appear to be related to the Investigator’s institutional responsibilities:

• no later than at the time of application for NIH-funded research;
• within thirty days of discovering or acquiring (e.g., through purchase, marriage, or inheritance) a new Significant Financial Interest; and
• at least annually during the period of award.

For further information and definitions of Significant Financial Interest and Financial Conflict of Interest, see Policy GP37. SFU is required to determine whether a Financial Conflict of Interest exists in respect to the proposed research and if so, to develop and implement a Management Plan that may include its reduction or elimination.

Each SFU Investigator or key personnel named in an application for new or continuing NIH funding must complete the following items prior to submitting their application, and if an award is made, must continue to do so regularly in accordance with NIH requirements:

• Financial Conflict Of Interest (FCOI) Tutorial
• Familiarize themselves with Policy GP37
• SFU Investigator's Statement of Financial Interests
• If applicable, the SFU GP 37: Conflict of Interest Disclosure Form

Public inquiries concerning identified Financial Conflicts of Interest on NIH grants should be addressed to the Director of Research Services.