I. Conflicts of Interest in Research

  1. Research activity in the University is dedicated to the advancement, preservation and dissemination of knowledge; instruction of undergraduate, graduate and postdoctoral students; advancement of the public interest and public welfare. Research dedicated to these ends may incidentally generate financial benefits to individual investigators and to the University, for example, through patents and licensing. This is to be welcomed. However, the prospect of such gain cannot be allowed to govern the selection and conduct of research projects. Choices concerning the nature and orientation of research must be based on University values, which include intellectual importance, educational merit and public benefit. It is thoroughly consistent with these values, indeed it is both necessary and desirable, for the University to seek outside support from government, industry, foundation and private sponsors. Sponsored projects should reflect a coincidence of research interests on the part of sponsors and University.
  2. Outside professional, financial and entrepreneurial activities of individual faculty and staff can contribute to University goals and provide valuable public and personal benefits as well. Primary commitment must however be devoted to the University. External interests and activities have to be ordered so as to minimize any risk of conflict with University objectives and values. It is not possible to lay down a precise and comprehensive set of rules on conflict of interest, even when the focus is narrowed to the research side of University life. A representative set of markers is nevertheless provided below. The Conflict of Interest in Research Panel (Panel), as set forth in paragraph I.13 below, is established to monitor and deal with issues of conflict. Faculty and staff are counted on, in the first instance, to monitor their own activities. Whenever they perceive that the question of conflict might arise, they are expected to disclose the relevant facts to the Panel as a basis for guidance, possible adjustments and expeditious resolution. These matters are described below.
  3. Student participation in research is a central educational goal of the University. The selection and involvement of students must therefore at all times be governed primarily by consideration of the students' own educational goals as well as the legitimate needs and objectives of the research project. Faculty and staff must at all times scrupulously avoid providing research guidance and facilities to students with the dominant aim of serving their own outside professional, financial and/or entrepreneurial activities and objectives.
  4. Open communication of research findings is an important University value. Outside sponsorship or other associations should not be a basis for inhibiting the publication or sharing of information. In the case of sponsored research, University researchers must retain full rights concerning the timing and content of publications, apart from those safeguards established by the University to protect privacy, proprietary information and patentable inventions.
  5. Research data and materials owned by or in the custody of the University, if they are to be made available externally, must be made generally available. In no case can the transfer of data or materials be made for reasons of personal gain, except in accordance with University policy on patents and copyright.
  6. The University does not accept research sponsorship predicated on the finding of predetermined research results.
  7. Except in the most incidental of ways, members of the University community should not use University research or administrative facilities to pursue personal business or commercial consulting activities.
  8. Research within the University may not be undertaken or oriented with the purpose of serving the interests of outside persons or organizations unless there is University approval and, typically, appropriate financial support from the same persons or organizations.
  9. Members of the University who enter into external consulting or other agreements must take care that these are not in conflict with the provisions of Princeton's patent policy, its obligations under any sponsored grant or contract, or any other policies of the University. 
  10. The risk of conflict of interest, or serious appearance of conflict, can arise when a University investigator (or his/her spouse or dependent children) has significant financial interests in an external enterprise engaged in activities closely related to the investigator's line of University research. It is the policy of the University to require faculty to complete an Annual Disclosure Form designed to identify any potential conflicts of interest arising from significant financial interests so that they may be appropriately managed. The University defines "significant financial interest" to include anything of monetary value rising to the level of significance, including but not limited to salary; other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options, or other ownership interests); or intellectual property rights (e.g., patents, copyrights, and royalties from such rights). By no means does the existence of such interests necessarily imply a conflict of interest. Nevertheless, where there are such interests, the investigator is obligated to provide full and current disclosure to the Review Panel. In exercising their judgment, members of the University are urged to tilt toward disclosure rather than nondisclosure in cases where they are unsure whether or not their outside financial interests rise to the level of "significant."
  11. Federal agencies funding research at the University have a legitimate interest in ensuring that the design, conduct and reporting of such research will be free from bias resulting from an investigator’s financial conflicts of interest. Often these federal agencies have specific regulations requiring certain disclosure of financial interests by principal investigators and key personnel applying for and working on federally funded research. The reporting requirements of federally funded research may be different than those ordinarily required by the University.   In those cases, the University will provide guidelines to assist Investigators in understanding their obligations as well as disclosure forms.
  12. Every University researcher is obligated to make appropriate disclosure as required by federal regulations or when, in the investigator's judgment and in the spirit of general University standards, there is a risk of conflict of interest or serious appearance of conflict. What is called for in such cases is full and current disclosure of all interests that bear on the particular instance of conflict. Wider disclosure of personal interests beyond that is not sought.
  13. The Conflict of Interest in Research Panel (Panel) is established as a committee reporting to the Dean for Research. The Panel is charged with receiving and analyzing disclosure material; proposing to the investigator suitable adjustments in project arrangements when these are deemed necessary to remove, minimize, or manage conflicts of interest; and developing policy recommendations on conflicts of interest for consideration by the URB or other appropriate University bodies. The Panel consists of ten members: the Dean for Research as chair, Dean of the Faculty, Dean of the Graduate School, Dean of the School of Engineering and Applied Science, General Counsel, and the Director of the Office of Technology Licensing and the Director of Research Integrity and Assurance, ex officio; three other tenured members of the Faculty, one from Division I or II, and two from Divisions III and/or IV, who are appointed by the Dean for Research in consultation with the Dean of the Faculty for staggered, renewable, three-year terms.
  14. Where external sponsorship of research is involved, there can be extra sensitivities concerning the potential for conflict of interest and, especially in the case of government sponsorship, conformity with agency regulations. For these reasons, the Review Panel reviews the annual conflict of interest disclosure statements from investigators involved in sponsored research.