​Conflict of Interest Policy (COI)

 Research funding from sources that have intellectual property interests in the research, or in which the PI has personal financial interest, may create a real or perceived conflict of interest, given the dual roles of the principal investigator in obtaining funding for the lab and as a mentor for graduate students. Issues of paramount importance are (i) the ability to publish results in a timely fashion; (ii) the ability to communicate research results openly, especially to members of the thesis committee; and (iii) academic rights to publish and speak freely, especially as related to a graduate student’s thesis and defense.

Statement of policy.

The following principles should apply to any situation involving a graduate student supported by funding that is associated with a confidentiality agreement:


    The limitations and nature of the confidentiality agreement must be fully disclosed to and approved by the student, the thesis committee, and the DBBS Associate Dean for Graduate Affairs;
    The confidentiality agreement must not place an unreasonable burden or delay in publication or reporting at scientific meetings;
    The confidentiality agreement must not delay the writing or defense of the thesis;

Examples of inappropriate projects:
1. Research involving chemical compounds whose structure or mechanism of action is proprietary and failure to disclose would preclude peer-reviewed publication.

2. Research involving genes or proteins whose original or modified sequences are proprietary and failure to disclose would preclude peer-reviewed publication.

3. Research involving organisms or cell lines that are proprietary and failure to disclose would preclude peer-reviewed publication.

4. Research in which the thesis advisor has a significant personal or corporate financial interest.


Process for handling potential conflicts of interest involving students
If a faculty member receives industry-sponsored research support that entails a confidentiality agreement or has a personal financial interest related to the thesis work, the following process must be followed in order for the graduate student to be supported by this source:

As soon as the proposed arrangement becomes a concrete plan, the faculty member and student involved discuss and sign an appropriately specific disclosure statement that is based on a standard template (see below).

The signed statement should be submitted to the DBBS Associate Dean for Graduate Education, who will review the material and forward a provisional recommendation to the Office of the Vice Chancellor for Research.

If approved by the Vice Chancellor for Research, the student may proceed with this research and receive industry-sponsored support pending final approval by the student’s thesis committee.

Once a thesis committee is established (or at the next scheduled thesis committee meeting if one already exists), copies of the disclosure statement are provided to the committee. The committee meets with the faculty advisor and student initially present and decides whether the constraints imposed by the confidentiality agreement are acceptable.

The thesis committee chair forwards its recommendation to the DBBS Associate Dean for Graduate Education by indicating on the disclosure statement whether or not the thesis committee approves the arrangement.

The DBBS Associate Dean for Graduate Education reviews the material and forwards a final recommendation to the Office of the Vice Chancellor for Research, where a final decision is made.

Disclosure statement for graduate students
Approved by Executive Council, DBBS
March, 2009
(Template; to be customized by the P.I. before presenting to the student)

Date:

From: PI
To: Graduate Student

This memo is to inform you that I intend to support $X of your salary with funds provided by company Y. In accepting this support, I am obliged to sign a confidentiality agreement that puts constraints on the release of proprietary information that may pertain to your research. Research findings generated in whole or in part by this support must be reviewed by company Y prior to public release by presentation at scientific meetings or submission for publication (abstracts or manuscripts). According to the terms of the grant, the maximum time the results may be held for review is Z days. It is my understanding that this delay will be the only restriction on publication of your research. [OR, if chemical structure or other information remains proprietary, spell out the specifics.] For your protection, this arrangement will be discussed with and must receive approval by your thesis committee, the DBBS Associate Dean for Graduate Education, and the Vice Chancellor for Research or his/her designee.

Signature of PI:__________________________________ Date:____________________

Signature of Trainee:_____________________________ Date:____________________

The thesis committee has reviewed the relevant material and [ ] approves [ ] disapproves of the proposed arrangement.

Signature of thesis committee chair:__________________________ Date:____________________

The Associate Dean for Graduate Education has reviewed the relevant material and [ ] approves [ ] disapproves of the proposed arrangement.

Signature of Associate Dean:________________________________ Date:____________________

The Vice Chancellor for Research has reviewed the relevant material and [ ] approves [ ] disapproves of the proposed arrangement.

Signature of Vice Chancellor of Research:_______________________ Date:____________________

(Signed copy should be returned to the Associate Dean for Graduate Education, DBBS, Campus Box 8226)
 
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