Institutional Conflict of Interest: Guidance for University Officials
Introduction
Penn State strives to ensure that its research, teaching, outreach, business transactions, and other activities are not inappropriately affected by, nor appear to be inappropriately affected by, the financial or business interests of the University or of University Officials or their spouses or partners. Policy AD83 aims to identify and manage conflicts of interest to ensure transparency, integrity, and unbiased decision-making within the University community.
Who Does AD83 Apply To?
Anyone who is designated as a “University Official” by the Conflict of Interest Official (COIO) must disclose the financial interests listed in policy AD83, if the financial interest is held by the University Official, their spouse, or their partner. Examples of positions designated as University Officials can be found in policy AD83.
What is an Institutional Conflict of Interest?
Institutional Conflict of Interest (ICOI) describes a situation where the financial or business interests of the University, or a University Official (or their spouse/partner), can affect or appear to affect the activities of the University, such as research, teaching, outreach, or business transactions.
Why is Disclosure Important?
Undisclosed and unmanaged institutional conflicts of interest have the potential to negatively affect public trust, harm the integrity of the University’s research enterprise, and/or could have potential legal or regulatory consequences.
What Am I Required To Disclose?
Income
- Income over 25,000 from for-profit entities held within the preceding 12-month period.
- Includes royalties, equity, consulting fees, honoraria, gifts, and other payments.
Public Equity
- Equity over $25,000 in a publicly traded company held within the preceding 12-month period.
- Includes stock, stock options, or any ownership interest.
- Excludes disclosure of investments in mutual funds and retirement accounts where the individual does not directly control the investment decisions.
Non-Public Equity
- Equity (any amount) in a non-public company.
- Includes stock, stock options, warrants, or any ownership interest.
Fiduciary Roles
- A fiduciary role (compensated and uncompensated) with a for-profit or non-profit entity.
- Includes, but not limited to, positions such as Member of the Board of Directors, Board of Trustees, CEO, CFO, Treasurer, etc.
What If I Have a Conflict?
If a potential conflict is identified, a disclosure will be presented to the Institutional Conflict of Interest Committee (ICOIC) for review. If the ICOIC determines there is a real or perceived conflict of interest, they may create a management plan which will include terms and conditions an individual must follow to ensure any ICOI is managed, reduced, or potentially eliminated.
Questions?
Please contact COI Staff at coinsadmin@psu.edu.