Policy on Financial Conflict of Interest

APPENDIX A

For Principal Investigators and Co-Investigators of NIH & NSF Proposals and Grants Only

DEFINITION OF SIGNIFICANT FINANCIAL INTEREST

EFFECTIVE AUGUST 24, 2012

For purposes of Pace University’s Policy and Procedures on Financial Conflict of Interest Related to NIH and NSF Externally Sponsored Projects, the term “Significant Financial Interest” includes any of the following interests of the disclosing individual (and those of the disclosing individual’s spouse and dependent children) that reasonably appear to be related to the disclosing individual’s responsibilities to Pace University (e.g., teaching, research, research consultation, professional practice, institutional committee membership, service on panels such as Institutional Review Boards): 

•                With regard to any publicly traded entity, a Significant Financial Interest exists if the value of any remuneration (salary or other payment for services) received from the entity in the 12 months preceding the disclosure and the value of any equity interest (including any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value) in the entity as of the date of disclosure, when aggregated, exceeds $5,000. 

•                With regard to any non-publicly traded entity, a Significant Financial Interest exists if the value of any remuneration (salary or other payment for services) received from the entity in the 12 months preceding the disclosure, when aggregated, exceeds $5,000, or when the disclosing individual (or the disclosing individual’s spouse or dependent children) holds any equity interest (including any stock, stock option, or other ownership interest) in the entity.

•                Intellectual property rights and interests (e.g. patents, copyrights), upon receipt of income related to such rights and interests.

•                The occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the disclosing individual and not reimbursed to the disclosing individual so that the exact monetary value may not be readily available).

Notwithstanding the foregoing, the term Significant Financial Interest does not include:

•                Salary, royalties or other remuneration from the University if the disclosing individual is currently employed or otherwise appointed by the University, including intellectual property rights assigned to the University and agreements to share in royalties related to such rights.

•                Income from investment vehicles, such as mutual funds and retirement accounts, as long as the disclosing individual does not directly control the investment decisions made in these vehicles.

•                Income from seminars, lectures or teaching engagements sponsored by a Federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001 (a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

•                Income from service on advisory committees or review panels for a Federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001 (a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

•                Travel that is reimbursed or sponsored by a Federal, state, or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

 

Appendix B – (Exhibit II in Pace University Policy and Procedures on Financial Conflict of Interest)

For Principal Investigators and Co-Investigators of NIH & NSF Proposals and Grants Only

PACE UNIVERSITY

Significant Financial Interest Disclosure Form

(To be used for initial and annual disclosures and also whenever a new Significant Financial Interest arises.)

  1. I have Have you read and do you understand Pace University’s Policy and Procedures on Financial Conflict of Interest Related to NIH and NSF Externally Sponsored Projects?

YES                                                             NO       

  1. Do you, and/or your spouse and/or dependent children, have any “Significant Financial Interest(s)” within the meaning of the Policy and Procedures on Financial Conflict of Interest Related to NIH and NSF Externally Sponsored Projects as set forth on the attached Appendix A?

YES                                                             NO       

If yes, please provide details, including

  • With respect to remuneration from, or any equity interest in, any publicly-traded entity, the name of the entity, and type and value of remuneration and/or equity interest;

 

  • With respect to remuneration from, or any equity interest in, any non-publicly traded entity, the name of the entity, and type and value of remuneration and/or equity interest;

 

  • With respect to intellectual property rights and/or interests (e.g. patents, copyrights), the nature of such interests and the nature of any income derived therefrom; and/or

 

  • With respect to externally- reimbursed or -sponsored travel, the purpose of the trip, identity of the reimbursing or sponsoring organization, the destination and the duration:

Signature              ________________________________________________

 

Printed Name     ________________________________________________

 

Date                         ________________________________________________

 

 

 

 

POLICY AND PROCEDURES ON FINANCIAL CONFLICT OF INTEREST