Conflict of Interest Policy
FOR FACULTY AND ACADEMIC STAFF APPLYING FOR
CARLETON-ADMINISTERED FEDERAL GRANTS
July 2002
- SCOPE. The following statement of policy applies to each member of the faculty or academic staff applying for a Carleton-administered grant from a federal agency or foundation. The policy was developed in response to 1995 federal rules governing institutional and researcher responsibilities in identifying and monitoring conflicts of interest. By assuming this responsibility for themselves, colleges and universities may avoid outside monitoring and regulation by the federal government.
- FIDUCIARY RESPONSIBILITIES. Employees, officers, and members of the board of the College serve the public trust and have a clear obligation to fulfill their responsibilities in a manner consistent with this fact. All decisions of the board and officers of the administration and the faculty and academic staff are to be made solely on the basis of a desire to promote the best interests of the College and the public good. The College’s integrity must be protected and advanced at all times.
College faculty or academic staff applying for outside grants may be involved in the affairs of other institutions and organizations. It is unlikely that an effective faculty will consist of individuals entirely free from at least perceived conflicts of interest. Although most such potential conflicts are and will be deemed to be inconsequential, it is everyone’s responsibility to ensure that the College is made aware of situations that involve business relationships that could represent a conflict of interest with respect to an outside grant. Thus the College requires that at the time of application for a grant for College-administered funds from a federal agency (and annually for the duration of the grant if it is funded) each applicant (1) review this policy; (2) disclose any possible business relationships that reasonably could give rise to a conflict of interest for the investigator or a member of his or her family; and (3) acknowledge by his or her signature that he or she is in accordance with the letter and spirit of this policy.
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DISCLOSURE. Faculty or academic staff are required to list on this form only those substantive business relationships (i.e., a financial interest exceeding $10,000 or 5% ownership) that he or she maintains (or members of their family maintain) with organizations or companies that might be affected by their research. In the event that a faculty member is uncertain as to the appropriateness of listing a particular relationship, the Dean of the College, as Institutional Grants Administrator, should be consulted. For purposes of this policy, family members include the spouse or dependent children of the investigator.
Conflicts of interest frequently are matters of degree and judgment, and the institution expects faculty and academic staff to be alert to the possible effect of outside activities on the integrity of their decisions and on their ability to fulfill their obligations to the institution and/or to funding agencies. As potential or actual conflicts of interest arise, the Institutional Grants Administrator will determine which conditions or restrictions might be imposed to manage, reduce, or eliminate actual or potential conflicts of interest.