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Conflict of Interest and Commitment
For Rutgers, conflict of interest (COI) refers to situations in which an individual holds a financial interest that can reasonably create the perception that the interest could affect the integrity and objectivity of the individual’s work. For example, a significant ownership position in a foreign company by a researcher that operates in a field related to her research could reasonably be perceived to have influenced her research in order to make the company more valuable.
Conflict of commitment (COC) generally refers to situations in which an individual dedicates time to non-Rutgers activities in excess of the time permitted by law or policy, or to other activities which reasonably may be perceived to influence the individual’s primary responsibilities to Rutgers. For example, a full-time Rutgers employee who also holds an appointment at a foreign institution may raise concerns about intellectual property ownership, dedication to Rutgers, and other issues that may be a conflict of commitment.
In most situations, conflicts of interest and commitment can be managed to help protect the credibility of the work being done and the reputation and integrity of our people and the University, and the first step in helping manage those conflicts is disclosure. Most of the recent enforcement actions by the federal government have resulted from failure by the individuals in question to disclose their relationships and seek an appropriate management plan. At Rutgers, the units processes used to assist our community include:
Conflict of Interest (COI) in Research
Federal guidelines and Rutgers policies require that an actual, perceived, or potential conflict of interest (COI) in research be eliminated or mitigated. Research personnel involved in the design, conduct, or reporting of research have an institutional responsibility and must disclose any financial interests or relationships that could result in a COI.
All Rutgers and Non-Rutgers personnel who are involved in the design, conduct, or reporting of research at Rutgers must complete an eCOI certification when the following occur:
On submission of an initial IRB application for proposed human subject research;
Annually as part of the IRB continuing review of an approved research study;
At the time of a funded research project; and
Within 30 days of discovering or acquiring new interests with respect to COI.
Please review Rutgers’ policies on conflicts of interest in research for more information.
Conflict of Interest – Other
In addition to conflicts of interest in research, a number of other laws, regulations, and policies may govern the disclosure and review of our outside relationships. Rutgers University is committed to ensuring compliance with the New Jersey Conflicts of Interest Law, the University Code of Ethics, and other University policies. Further information regarding potential conflicts of interest including outside employment, consulting, speaking engagements, attendance at events, royalties, employment of relatives, and other topics is available or from University Ethics and Compliance at 973-972-8000.
Conflict of Commitment
Conflict of commitment describes a situation in which a faculty or staff member participates in an outside professional activity, whether paid or unpaid, that requires the employee’s time in a way that may interfere with or appear to interfere with the employee’s obligations and responsibilities to Rutgers, even when that activity may seem to benefit the University or the employee’s personal and professional development.
In accordance with University Policy 60.4.2 Code of Ethics for Administrative and Professional Staff Members, Policy 60.5.8 Conflicts of Interest – Faculty Professional Activities Outside the University and Outside Employment for Academic Personnel, Policy 60.5.9 Faculty or Staff Involvement with Commercial Enterprise – Contracts with the University, and Policy 90.2.5 Investigator Conflict of Interest, members of the Rutgers community are expected to avoid situations that would create a conflict between the University’s interests and the individual’s other outside interests.
Use the University’s eCOI and Ethics Armor systems to disclose these outside professional activities, and be sure to discuss them with appropriate supervisory personnel. If you’re unsure about whether to disclose a particular activity, either simply disclose the activity for review or discuss it with your supervisor and/or the University’s Ethics Office (email@example.com) in advance. Through the process of disclosure, discussion, and approval, Rutgers is best positioned to implement an appropriate management plan that protects the reputations of our personnel and the University from the suggestion of bias in our activities.
We recognize that faculty with unconventional appointments such as part-time appointments will have different expectations and requirements. We advise you to work directly with your department chair and/or the Ethics Office to discuss this topic in greater detail.