星空传媒

 A COI exists when a faculty or staff member鈥檚 financial or personal interests may compromise鈥攐r appear to compromise鈥攖heir objectivity in fulfilling university responsibilities. Examples include:

A faculty member has a financial interest in a company that could benefit from their research.
A staff member is involved in purchasing decisions for a company where they have personal relationships.

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 A COC occurs when external activities interfere with an employee鈥檚 ability to meet their university employment obligations. Examples include:

A faculty member spends significant time on a private consulting project, affecting their teaching duties.
A staff member takes on an additional part-time job that conflicts with their university work hours.

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Covered Employees include all faculty, SAAO/EPS staff, and anyone involved in federally funded research. Back to top

Generally, an External Professional Activity for Pay should be limited to no more than twenty percent (20%) of your contracted time. Back to top

Yes, adjunct faculty are considered Covered Employees and must complete the annual disclosure and research-specific portions of the disclosure. Adjuncts do not have to complete the External Professional Activities for Pay section, and that section will not show up for them in their disclosure. Back to top

Disclosures are required:

Annually, even if you have nothing to report
When initiating a new externally funded research project
When there is a change in financial interests or external activities

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Yes, all individuals covered by the policy are required to complete the annual disclosure. If you are not currently conducting research and have no plans to submit a proposal for funding in the coming year, you may indicate so in the questionnaire. Back to top

Yes, all individuals covered by the policy are required to complete the annual disclosure, even if you have nothing to report. Your response to the questionnaire will serve as documentation that you do not have any significant financial interests or other potential conflicts. Back to top

 The questions in the disclosure form will help guide you. Additionally, the COI policy details categories of potential conflicts, including activities that are generally allowable but must be disclosed; activities requiring disclosure for further review and analysis; activities that are generally not allowable or permitted unless a management plan is in place; and activities that are not allowable under any circumstances. Back to top

External interests, including personal financial, commercial, or business interests, that are related to or overlap (or may have the appearance of doing so) with your 星空传媒 role(s) and activities must be reported. This includes, without limitation, off-campus, non-University commitments, such as company ownership, a board or management position, or consulting activities for external entities. In addition, any personal relationships that overlap with your institutional role must be reported. This would include, for example, supervising an immediate family member who is an employee at the University. Back to top

 Use the to complete and submit your disclosure. Back to top

 The Chief Compliance Officer (CCO) has the initial responsibility to review potential conflicts identified in the disclosure. The CCO will then route the disclosure, along with their recommendation to approve or not approve, to your supervisor for review. If the supervisor agrees with the CCO鈥檚 recommendation, the recommendation is approved and you are notified of the approval and any required actions. If the supervisor disagrees with the CCO鈥檚 recommendation, they must explain their reasoning and the disclosure is referred to the COI Panel for further review. The COI Panel may accept or reject the supervisor鈥檚 decision or request additional measures to resolve or manage the conflict. Back to top

In many instances a conflict can be resolved by simple disclosure. In other cases, the conflict may be monitored by an assigned monitor, or a management plan may be needed. In that case, the supervisor and the COO will work with you to develop a proposed management plan for review and approval by the COI Panel. A management plan is a strategy used to mitigate or eliminate a conflict and is tailored to your specific situation. Sometimes, severance of a relationship that is creating the actual or potential conflict might be the only viable option. Back to top

No, external activities are not automatically considered a conflict of interest. The questions in the disclosure will help determine whether a conflict exists. Generally, an external activity may present a conflict if any of the following circumstances are present:

The external activity takes up more than twenty percent (20%) of the time you are supposed to be spending on 星空传媒 employment responsibilities.
You are not able to carry out your primary employment responsibilities in a timely and effective manner.
You are being paid by the external entity and the University to do the same work.
You are exploiting University resources (equipment, supplies, facilities), which members of the public are generally not permitted to use, for your external activities.
The external entity does business with the University, and you may not be able to perform your 星空传媒 duties impartially as a result.

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Yes. All Covered Employees must complete the training that is integrated into the disclosure form. Research personnel must also complete project-specific CITI training. Answering the disclosure screening questions helps the Research Compliance Officer determine what additional CITI training you need, and how often. Back to top

External Professional Activities for Pay must be disclosed at least ten (10) calendar days before beginning the activity. The disclosure form includes questions about external activities, and you can update your electronic disclosure at any time. Back to top

If you try to enter an Entity Name that does not appear in the drop-down list, that is because it is not yet in the system and you will have to add it. If the entity you want does not appear in the drop-down list, enter Not Found in the search box and select it. Once you do that, you can manually type in the name of the entity in the next field, called Entity Name Not Found. Here is a screenshot:

 

You will only have to do this once, as now that entity will be added into the system and will be available in the drop-down menu for future submissions.

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 Under the 鈥淎nnual Disclosure Questions鈥� tab, you would answer 鈥淵es鈥� to the following question: 鈥淒uring the past 12 months, or in the next 12 months, did or will you or a member of your immediate family serve as a member of the Board of Directors or as an officer for any entity that is related to your 星空传媒 activities, including research activities? (This includes but is not limited to: CEO, COO, President, Vice President, Scientific Officer/Advisor, other management positions with a fiduciary responsibility, partner, or trustee.)鈥� On the 鈥淓ntities鈥� page, add your LLC and answer the questions about your ownership in the LLC. On the 鈥淓xternal Activities for Pay鈥� tab, disclose each of your clients for whom you actually perform the external consulting work. Back to top

One example is if you are paid by 星空传媒 to attend a conference and also receive payment from an external sponsor for the same conference. Another example is if an external sponsor is paying for you to submit a journal article and you are also using that journal article as part of your 星空传媒 scholarship. Back to top

 If the estimated royalties generated by the students in your course(s) exceeds $100, please donate the estimated royalties or payments received to a 星空传媒 student-benefiting fund. Some examples are a departmental scholarship or the Student Emergency Fund. We suggest you  maintain records related to this donation. Please note that new textbooks, e-books, and educational materials that are not textbooks are also covered. Used textbooks or textbook rentals are not expected to generate royalties. We know it can be difficult to determine the royalty amount but give your best estimate. Back to top

 If you invest and are unaware of the specific funds your money is invested in (for example retirement accounts like TIAA CREF), you don鈥檛 need to disclose. This is because you can鈥檛 be influenced if you don鈥檛 know the sources of the funds and you do not directly control the investment decisions made. On the other hand, an example of when an investment may create a conflict is if you invest in a specific technology company and are also paid by that company to conduct research on their products. Back to top

Yes. If you have a financial or equity interest in any company that may reasonably appear to be related to your University responsibilities or your research at the University, this is considered a significant financial interest and must be disclosed. Back to top

No. Salary paid by 星空传媒 but derived from a grant from a collaborative institution or company is considered salary and should not be considered a significant financial interest for you to disclose. Back to top

Yes, you must disclose all sponsored or reimbursed travel related to your institutional responsibilities UNLESS the sponsor is any of the following:

• United States Federal, State or local government agency
• United States institution of higher education or United States research institution
• Academic teaching hospital or medical center affiliated with any of the above

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This would include :

• Interests that are similar to or take advantage of your position, activities or expertise at the University. For example, you maintain a consulting practice in an area for which you are similarly responsible for developing and/or managing on behalf of the University (e.g., fundraising).
• Outside interests that take advantage of your access to University-owned information or intellectual property, resources, or personnel, such as if your external activity licenses (or should license) or otherwise uses the University鈥檚 information or intellectual property.
• Outside interests that use the information or intellectual property that you acquired or use in connection with your institutional activities. For example, if you are a researcher in the field of virology, your outside activities in connection with a viral vaccine will be deemed to be related to or overlap with your institutional activities.

If you are not sure whether an outside interest relates to or overlaps with your institutional activities, please reach out to coi@wcu.edu.

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A: For purposes of the disclosure form, you only need to disclose royalties or other payments, or any intellectual property rights, that result from or are related to your 星空传媒 work, and for which you are doing any of the following:

• Conducting or planning to conduct research
• Directly involved in University purchasing decisions
• Using any of these intellectual property holdings as part of your University employment responsibilities
• Requiring purchase of this intellectual property in a course you teach

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