Conflict of Interest

• Policy Requirements: Auburn University intends "to manage financial conflicts of interest of its employees as part of ongoing efforts to prevent outcomes that may be harmful to sponsored activities, operation of regulatory compliance committees, technology transfer efforts, or the University at large. Therefore, employees responsible for the design, conduct or reporting of Sponsored Research, engaging in Technology Commercialization, and/or Related Activities (Affected Employees) must report Significant Financial Interests and must work with the University to develop a plan to Manage Financial Conflicts of Interest as necessary." (AU FCOI Policy for Research and Related Activities. Approved by Act of the University Senate, January 13, 2015.)

• Policy Principles:

  • "The integrity of the University as a community of scholars requires the open exchange of ideas in an atmosphere free from financial conflict and undue influence. This is especially important in those cases where relationships with external parties could lead to circumstances adversely impacting scholarly work, integrity, judgment or the conduct of sponsored activities." (FCOI Policy)

  • "Auburn acknowledges that Affected Employees and their Immediate Family have the right to acquire personal financial assets and to establish financial relationships with outside entities. However, Affected Employees also have the responsibility to manage their financial affairs and relationships in a manner that does not interfere with, or improperly influence, the performance of their professional duties and responsibilities. As long as Significant Financial Interests are disclosed and financial conflicts are managed, reduced, or eliminated; they need not be a problem." (FCOI Policy)

• Primary Goal: AU adopted the FCOI Policy "to ensure that faculty and other employees are made aware of [FCOIs], are dutiful in internally disclosing Financial Interests, and that identified conflicts receive scrupulous attention and management." (AU Procedures for FCOI Policy for Research and Related Activities. Approved by Act of the University Senate, January 13, 2015.)

• Applicability: The AU FCOI Policy requires disclosure of significant financial interests to the University at certain times by "Affected Employees," defined by involvement in:
  
  
  • Sponsored Research: "Faculty (as outlined in the Faculty Handbook) and other employees responsible for the design, conduct or reporting of sponsored Research....This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)

• • Technology Commercialization: "Faculty (as outlined in the Faculty Handbook) and other employees....engaged in technology commercialization activities. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)

• • Related Activities: "Faculty (as outlined in the Faculty Handbook) and other employees....engaged in any activity which has the potential to improperly influence sponsored Research or Technology Commercialization. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)

• Principal Investigator Training and Disclosure Oversight Responsibilities

  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project, subject to the FCOI regulations, Principal Investigators are responsible for:

    1. Identifying Investigators on a proposal, award, and modification to the scope of work, and

    2. Ensuring Investigators take FCOI Training (PHS and DOE awards) and submit FCOI Disclosure Questionnaires (all awards).

  • The PI, Co-PI, PD, Co-PD, and Senior/Key Personnel named in a funding proposal, award, progress report, award modification, subaward, subgrant, or subcontract are always considered an Investigator.

• COI Checklist 

  • Prior to expending any funds under a sponsored research project:

• Sponsored Research: PI Disclosure Oversight Responsibilities

  • Continuing Responsibilities: On a timely basis, from the award stage throughout the duration of a research project, subject to the AU FCOI Policy, Principal Investigators are responsible for:

• • Affected Employee engaged in Sponsored Research: Consult the Guide to Identifying Affected Employees Subject to the AU FCOI Policy to determine which persons on a sponsored research project are Affected Employees.

    • The PI, Co-PI, PD, and Co-PD named in a funding proposal, award, progress report, award modification, subaward, subgrant, or subcontract are always considered Affected Employees.

• Technology Commercialization: Affected Employee Disclosure Questionnaire Filing Responsibilities.

  • Continuing Responsibilities: On a timely basis, when planning to participate (and definitely before participation) in Technology Commercialization activities subject to the AU FCOI Policy throughout the duration of the Technology Commercialization activities, Affected Employees are responsible for submitting FCOI Disclosure Questionnaires. 

  • Who is an Affected Employee Engaged in Technology Commercialization Activities? 

Multiple Research Sponsors: 

• If you have multiple funding sponsors, you do not need to submit multiple disclosure questionnaires at the same time and/or for the same purpose.

• Depending on the requirements of your multiple funding sources and/or AU policy, however, you may need to revise/recertify your disclosure one or more times.

  • For example, if you are a PHS Investigator and have submitted an annual disclosure questionnaire, you need not submit a completely new disclosure questionnaire upon receiving an award from a private sponsor. However, if your significant financial interests have changed since your most recent annual disclosure, you must revise the disclosure to ensure that the information is accurate and complete; this enables timely management, reduction, or elimination of any potential, perceived, or actual financial conflict of interest.

• Related Activities: Affected Employee Disclosure Questionnaire Filing Responsibilities.

  • Continuing Responsibilities: On a timely basis, when planning to participate (and definitely before participation) in Related Activities subject to the AU FCOI Policy and throughout the duration of the Related Activities, Affected Employees are responsible for submitting FCOI Disclosure Questionnaires. 

  • Who is an Affected Employee Engaged in Related Activities?

• When to Disclose: 

  • Annually

    • Full-time Auburn employees:  All full-time employees are required to complete an annual disclosure. Disclosures comprise significant financial and other interests that reasonably relate to the employee's institutional responsibilities and should be updated annually and within 30 days of discovering any new interest or relationship.

    • Auburn students: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

    • External individuals: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

• How to Disclose: All annual disclosures must be submitted online through the Endeavor platform.​

  • Endeavor Users.

    • Helpful Guide for Auburn employees: Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 

    • Auburn students: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

    • External individuals: Please contact endvcoi@auburn.edu if you need to submit a disclosure.

       

• When and How to Train: Online via CITI 

  • Certain research sponsors require FCOI training. PHS and DOE require FCOI training for all Investigators. AU offers agency-specific training through our CITI Program Training platform.

  • Voluntary Conflict of Interest training is available to all researchers and strongly encouraged by the University. Consult the CITI Single Sign-On page for additional information about how to access AU CITI Training.