Here you will find information about what constitutes a financial conflict of interest related to research, a non-research-related conflict of interest, and a conflict of commitment. You will also find some examples of each of these conflicts, and some basic information about how they are reviewed and managed at Cornell. Additional information can be found in Cornell Policy 1.7 on Financial Conflicts of Interest Related to Research, and the complementary Cornell Policy 4.14 on Conflicts of Interest and Commitment.
What are financial conflicts of interested related to research?
Financial conflicts of interest are addressed by Cornell Policy 1.7.
A Real Financial Conflict of Interest exists when a financial interest – or other opportunity for personal financial gain – is likely to compromise or influence the objective design, conduct, reporting, or direct administration of research.
An Apparent Conflict of Interest exists when there is a reasonable apprehension, which reasonably well-informed people are likely to have, that an individual's opportunity for personal financial gain could compromise or influence the design, conduct, reporting, or direct administration of research.
Below are a few sample cases reflecting conflicts of interest related to research. For additional examples, and more details about considerations and methods of managing the conflicts, check out this set of COI Case Studies.
Noah Brown is a professor in Chemical Engineering and an expert in food safety, and he consults for a company called FoodSafety, Inc. FoodSafety, Inc. wants to award a research grant to Cornell with Professor Brown as PI.
COI Determination: Research funding from a company in which a faculty member has a financial interest presents an allowable conflict of interest that can be managed using standard terms.
Amanda Smith is an Assistant Professor in the College of Veterinary Medicine, and she has invented a genetic testing toolkit for cats. She started a company called "Pawgenes," which has licensed the IP from Cornell; however, Pawgenes does not have lab space to carry out R&D. Pawgenes raises money and wants to provide $100,000 in sponsored funds to Cornell, with Professor Smith serving as PI on the award. The Smith lab, staff, and students have the tools and expertise to help Pawgenes with their R&D, and the money could help fund a student in the lab.
COI Determination: Research funding from a company in which a faculty member has an ownership interest is also an allowable conflict of interest, but will require closer management and strict oversight (including the naming of a co-PI on the award).
- Samantha, 4th year PhD student (GRA on federal funds, almost done with her thesis work, scheduling her B exam soon)
- Andrew Gates, faculty (Samantha's Special Committee Chair and PI on grant that funds her)
Professor Gates and Samantha have co-invented a technology that is expected to have large market potential, and Cornell’s Center for Tech Licensing (CTL) has begun the patenting process. Samantha and Professor Gates decide to start a company together to license this tech from CTL. Each will take 50% equity in the company, Samantha will work on this as she is finishing up her PhD, and Professor Gates will use his “one day a week consulting allowance” to work on the company’s business.
Potential Problems: Faculty guidance to students must be governed primarily by the academic interests of the student, not by considerations of personal financial gain. In this scenario, there is the possibility of Professor Gates:
- permitting or advising Samantha to spend too much time on company activities;
- directing Samantha's research toward a topic of interest to the company; or
- treating--or appearing to treat--Samantha more favorably than other students
COI Determination: A student and her/his faculty supervisor cannot be involved in outside financial activities together while in an academic relationship, unless there is strict management and oversight.
How are financial COIs related to research reviewed and managed?
For information about how financial conflicts of interest related to research are identified, reviewed, and managed, please visit our page on this topic.
What are non-research-related conflicts of interest?
Non-research-related conflicts of interest are addressed by Cornell Policy 4.14.
A non-research-related conflict of interest may arise when a person has the opportunity to influence Cornell's business, administrative, academic or other decisions in ways that could lead to personal gain or advantage of any kind. Members of the university community should be conscious of possible conflicts or the appearance of such conflicts if they are involved in: the procurement, exchange or sale of goods, services or other assets; the negotiation or formation of contracts or other commitments affecting the assets or interests of the institution; the handling of confidential information; and the rendition of professional advice to the University.
The following are examples of activities that have the potential to create non-research-related conflicts of interest. Such activities should be reported to the COI office and reviewed prior to being undertaken. To see a more comprehensive list of such conflicts, see Cornell Policy 4.14.
- An individual possesses a significant financial interest in or participates in the profits of any organization that deals or seeks to deal with the university.
- An individual is concurrently engaged to teach a course or otherwise make a substantial contribution to the instruction or educational services offered by another entity. (Instructional activities performed during sabbatical leave are not included, nor are instructional activities conducted for a subsidiary of Cornell.)
- An individual makes substantial use of university resources (e.g., studios; computer technology; research, technical, or support staff) in developing and/or teaching a course offered by another entity.
- An individual uses their authority to require others at Cornell to purchase a product in which s/he has a proprietary interest and from which s/he will receive income.
- An individual is asked to assume executive or managerial positions with outside organizations that might seriously divert the individual's attention from university duties, or create other conflicts of loyalty.
How are non-research-related conflicts of interest reviewed and managed?
During the annual conflict of interest reporting cycle, all reporters will provide information about their outside relationships. This information is then shared--minus financial details--with unit heads (e.g., deans, directors, vice provosts). Is it the responsibility of the unit head to address issues of non-research-related conflicts of interest. In the event that reported information reveals a real or perceived conflict, the unit head or designee will review the facts and manage the conflict.
What are Conflicts of Commitment?
Conflicts of Commitment are addressed by Cornell Policy 4.14.
A Conflict of Commitment occurs when a Cornell employee engages in an outside activity that burdens or interferes with their fulfillment of primary commitments and obligations to Cornell, even if the outside activity is valuable to the university or contributes to their professional development and competence. Regardless of dollar amount, a Cornell employee's external commitments or financial interests with an external entity (such as employment, service or consulting, or intellectual property or licensing) may constitute a conflict of commitment.
- External commitments, whether compensated or in a volunteer capacity, that involve frequent or prolonged absence from Cornell on non-university business
- External commitments that engage a substantial portion of the time an individual is expected to spend on Cornell-related activities
How are conflicts of commitment reviewed and managed?
During the annual conflict of interest reporting cycle, all reporters will provide information about their outside commitments. This information is then shared--minus financial details--with unit heads (e.g., deans, directors, vice provosts). Is it the responsibility of the unit head to address issues related to conflicts of commitment. In the event that reported information reveals a real or perceived conflict of commitment, the unit head or designee will review the facts and manage the conflict.
Do you need help or more information?
For any questions about conflicts of interest or commitment, including what constitutes a COI or COC, reporting, or the review and management process, please contact the COI office.
For any COI-related concerns and how to deal with them, please visit our "Report a COI Concern" page .