Conflict of Interest
A conflict of interest (COI) occurs when an individual's professional actions or decisions at the University may be influenced by personal interests, typically financial, arising from outside obligations or activities. The key principle in managing COI is transparency. The first step in addressing a potential conflict is the disclosure of the interest to the relevant University of Alaska Fairbanks administrative office.
A working definition from the U.S. Department of Health and Human Services (HHS), Office of Research Integrity (ORI), describes a conflict of interest as a situation where financial or other personal considerations may compromise or bias professional judgment and objectivity.
The National Institutes of Health (NIH), under Part 2640, defines a conflict of interest (COI) as occurring when a government-related matter, including research, could directly and predictably affect the financial interests of an individual, their spouse, minor children, general partners, or certain organizations in which the individual holds a position such as officer, director, trustee, general partner, or employee. This also includes entities with which the individual is negotiating or has an agreement for potential employment.
A conflict of interest can occur under numerous scenarios when an individual's personal interest could compromise their judgment, decisions, or actions in relation to their job.
A situation in which an individual's professional actions or decisions at the university may be influenced by personal interests, particularly financial ones, outside of their university responsibilities. COIs can compromise the objectivity of decisions and actions.
A situation where an individual’s external obligations or activities (e.g., consulting, outside employment) could interfere with or diminish their ability to fulfill their responsibilities to the university, particularly regarding time and effort allocated to university duties.
A situation where a reasonable person could believe that an individual's professional judgment might be influenced by personal interests, even if no actual bias exists. This perception can damage trust in the individual or institution.
A situation where a personal or financial interest has not yet affected research or decision-making but may do so in the future. Disclosure and management of potential COIs are important to prevent issues from arising.
A type of COI where a researcher’s financial interests, such as compensation, equity ownership, or royalties, may influence or appear to influence their professional judgment or research outcomes. This includes personal financial gain from industry or companies involved in the researcher’s work.
Refers to financial interests that could potentially influence or appear to influence an individual's professional judgment or decision-making. This includes compensation, equity ownership, stock options, or royalties that exceed certain thresholds, as well as positions in companies that may be related to the individual's research or academic responsibilities. Disclosure of significant financial interests helps to manage potential biases and maintain the integrity of research and academic work.
Financial conflicts of interest are common in research universities and may be inevitable. Collaborations between academic researchers and industry can be mutually beneficial, advancing the university’s research mission and the research goals of industry. These collaborations often take the form of consulting or sponsored research agreements. Universities also play a key role in stimulating economic development and transferring discoveries to the private sector through commercialization, such as licensing technologies to industry or supporting companies founded by academic inventors.
While these opportunities provide valuable financial rewards for researchers, they also carry the risk of influencing research direction, compromising data objectivity, and distorting the interpretation of results. Even if a researcher believes their financial interests do not pose a risk, the perception of bias can be just as damaging as actual bias, affecting both the researcher’s reputation and the university’s integrity.
Conflict of interest occurs when a university's financial interests or external relationships could influence, or appear to influence, its research, academic decisions, or operations. This can happen if the university stands to benefit financially from research outcomes or industry partnerships, potentially affecting objectivity and integrity. Managing ICOIs is essential to maintaining trust in the institution’s work.
University officials should report the following interests:
- Royalties or other payments from licenses or other technology transfer agreements related to University intellectual property rights from a for-profit company
- Payments (e.g., salary, consulting fees, honoraria, gifts, etc.) received from a for-profit company
- Any equity or other ownership in a non-publicly traded company
- Any position giving rise to a fiduciary duty in a for-profit company
Refers to any financial compensation, benefits, or other forms of remuneration received by an individual that could potentially influence, or appear to influence, their professional judgment, decision-making, or actions. In the context of research or academic work, compensation from external sources—such as industry partnerships, consulting fees, equity ownership, or royalties—may create a conflict if it affects or could be perceived to affect the individual's objectivity or integrity in their university-related responsibilities. It is important to disclose such compensation to ensure transparency and maintain the credibility of the individual's work and the institution.
Given the growing concerns about international research engagements, transparency is essential to maintaining the integrity of the research process. We understand that knowing what needs to be disclosed to the university can sometimes feel confusing, inconvenient, or burdensome. The following guidelines are designed to help clarify your responsibility to disclose outside interests.
Please keep these two key rules in mind when determining what to disclose:
- The external activity or interest must be related to your university responsibilities or academic discipline.
- This applies not only to you but also to your spouse and dependent children.
Please review the following list of activities and interests that require disclosure to the university. If you have questions, feel free to contact our office. Note that this list is detailed but may not include every possible scenario.
Exclusions:
The following do not need to be disclosed:
- Income from seminars, lectures, or teaching for government agencies or higher education institutions (including affiliated labs/medical centers).
- Service on advisory/review panels for these institutions.
- Salary from the institution
- Income from authorship of academic works
- Income from mutual funds and retirement accounts
Common Sources of Disclosures:
External personal compensation
- Any payments for consulting, advisory boards, employment, etc.
- Licensing or royalty income from intellectual property
- Publishing royalties
- Talent programs
- Payments for teaching, lecturing, etc., at other institutions
- Foreign and domestic entities
Publicly traded stocks (NASDAQ, NYSE, Pink Sheets, etc.)
- Stocks in which you directly control the purchases and sales
- Not TIAA CREF, IPERS, or mutual funds
- Stock Options
- Dividends
Privately held equity (ownership)
- Ownership in a startup company
- Personal consulting business, etc.
- Stocks or percent of ownership
- Stock options
- Includes foreign and domestic startup companies
Other External Commitments (even if they are unpaid)
- External employment/side gig/second job/moonlighting
- Service on boards of directors, panels, advisory boards, etc.
- Speaking engagements
- Consulting
- Education presenter/recipient
- Teaching, lecturing, etc. at other institutions (foreign and domestic)
- Even if you don’t get paid
You must disclose the following:
Faculty and staff may engage in external employment, consulting, or professional activities outside their university duties. However, these activities must comply with university policies to ensure they do not create conflicts of interest or commitment that could interfere with UA responsibilities.
Example: A professor is invited to serve as a paid consultant for a private company in their field of expertise. Since the company has research ties to UA, they disclose the activity to ensure compliance with university policies.
The University of Alaska (UA) allows the employment of immediate family members but requires transparency and proper oversight to prevent conflicts of interest, favoritism, or bias. Employees must disclose family relationships if they are involved in hiring, supervision, or decision-making related to a relative’s employment.
Example: A department chair’s spouse applies for a faculty position within the same department. To ensure fairness, the chair discloses the relationship, and an independent committee oversees the hiring process.
- Spouse employed by an industry partner – Disclosing if your spouse is employed by, or receives payment from, a company that has contracts, sponsorships, or collaborations with the university or your research group.
- Dependent child with paid internship – Disclosing if your dependent child has a paid internship with a company or organization related to your field of research or academic responsibilities.
- Spouse receiving consulting fees – Disclosing if your spouse is compensated for consulting work for an external entity that could benefit from your research outcomes.
- Family member receiving royalties – Disclosing if a family member receives royalties or other income from intellectual property or patents that overlap with your research or university work.
- Family ownership in related business – Disclosing if a spouse or dependent child has ownership, stock options, or other financial stakes in a company that operates in your academic discipline or partners with the university.
The University of Alaska (UA) requires faculty and staff to disclose any financial or personal interests in contracts, grants, leases, or loans involving the university. This ensures transparency, prevents conflicts of interest, and maintains integrity in university business transactions.
Example: A faculty member owns a company that submits a bid for a university research contract. To ensure compliance, they disclose their interest and remove themselves from the selection process.(Unrestricted gifts/prizes, if applicable, prompt completion of form based on specific criteria.)
The University of Alaska (UA) has policies regarding the receipt of gifts to prevent conflicts of interest and ensure ethical decision-making. Employees must disclose gifts that could be perceived as influencing their professional duties or creating an obligation to the giver.
Gifts of nominal value (e.g., promotional items, plaques) are generally acceptable.
Gifts from vendors, contractors, or entities doing business with UA must be disclosed and reviewed if they exceed a certain value.
Cash gifts or personal benefits are not allowed if they create a conflict of interest.
Example: A university employee receives an expensive gift from a vendor bidding on a UA contract. To avoid any appearance of favoritism, they disclose the gift and follow UA’s policy for ethical review.
Employees traveling on University of Alaska (UA) business may have their travel expenses covered by an external organization. However, prior approval is required to ensure compliance with conflict of interest and ethics policies and to confirm that the funding does not create an obligation or undue influence.
Must receive advanced approval before accepting external payment for travel expenses.
Funding from vendors, contractors, or entities with business interests in UA requires review.
Travel support should align with UA’s mission and professional responsibilities.
Conference Travel Paid by a Company – Disclosing if a company pays for your travel, lodging, or meals to attend or present at a conference, especially if the company’s products or services are related to your research.
Industry-Funded Site Visit – Disclosing if a company that could benefit from your research funds your travel for a site visit to review their technology, facilities, or products.
Travel for Collaborative Research Meeting – Disclosing if an external organization, such as a foundation or corporate partner, sponsors your travel to attend a meeting related to a collaborative research project they are funding.
Sponsored Travel for International Collaboration – Disclosing if an international institution covers your travel expenses to visit their site for a research collaboration, especially if the organization has a financial stake in the research outcome.
Workshop Attendance Funded by a Nonprofit – Disclosing if a nonprofit organization that has interests related to your PHS-funded research pays for your travel and lodging to attend a workshop or training session.
Example: A faculty member is invited to speak at a conference, and the sponsoring organization offers to cover airfare and lodging. Before accepting, they submit a request for advanced approval to ensure compliance with UA policies.
An Ethics Determination Request is a formal process used to assess whether a proposed activity, relationship, or decision presents ethical concerns or potential conflicts of interest. It helps ensure that actions align with institutional policies, regulations, and professional ethical standards.
Example: A faculty member is offered a paid consulting role with a company that has research ties to their university. To ensure transparency and avoid conflicts, they submit an Ethics Determination Request for review before proceeding.
The University of Alaska (UA) requires faculty and staff to disclose significant financial interests (SFIs) that could create a conflict of interest in research, contracts, or decision-making. These include equity ownership, royalties, paid consulting, or substantial non-monetary contributions from external entities.
General threshold: $5,000 (includes combined payments for services or equity interests)
Travel paid by others for institutional responsibilities (excludes government agency or higher education sponsorship)
Intellectual property rights and interests of any amount
Example: A faculty member receives free laboratory equipment from a private company that could benefit from their research findings. To ensure compliance, they disclose the in-kind contribution and follow UA’s conflict of interest review process.
A Conflict of Commitment occurs when an employee’s outside activities or employment interfere with their primary responsibilities at the University of Alaska (UA). It arises when personal or professional engagements take up so much time or attention that they impact the quality or quantity of an employee’s work for the university.
Disclosure of international engagements and affiliations
Employees must disclose any outside employment or activities that may interfere with their university duties.
Activities that demand excessive time or attention, such as consulting, secondary employment, or significant volunteer roles, should be disclosed to ensure they do not negatively affect job performance.
Disclosures are necessary to ensure fair and ethical practices and to maintain institutional priorities.
Example: A professor is offered a part-time consulting position that requires significant travel and working hours, potentially interfering with their university teaching and research responsibilities. To avoid a conflict of commitment, they disclose outside employment for review.
An in-kind contribution is a noncash contribution provided by an external entity that directly supports the individuals’ research and development efforts.
An in-kind contribution may include but is not limited to real property, laboratory space, equipment, data or data sets, supplies, other expendable property, goods and services, and employee or student resources.
An in-kind contribution may include but is not limited to real property, laboratory space, equipment, data or data sets, supplies, other expendable property, goods and services, and employee or student resources.
In-kind contributions with an estimated value of less than $5000 need not be reported.
Example: A researcher receives donated software from a tech company for their university research project. Since the company could benefit from the research results, the researcher discloses the in-kind contribution to ensure transparency and prevent potential conflicts of interest.
Consulting for a company – Providing expert advice or services to an organization outside of UAF, whether paid or unpaid.
Serving on an advisory board – Participating in a committee or board for a company or nonprofit organization, with or without compensation.
Volunteering with a professional association – Taking on a leadership role or providing services to a professional group outside of UAF.
Serving as a director or officer of a company – Holding an official position, such as a board member or executive, in a company that is not affiliated with UAF.Freelance writing or speaking engagements – Writing articles, giving talks, or providing other services to external organizations for pay or as a volunteer.
Consulting for an international organization – Providing expert advice to a company, government, or nonprofit organization based outside of the U.S.
Collaborating with international researchers – Working on joint research projects with scholars or institutions located in other countries.
Serving as a board member for a foreign nonprofit – Holding a leadership position in a nonprofit organization located outside of the U.S.
Teaching or lecturing abroad – Giving a course, seminar, or presentation at a university or academic institution in another country.Participating in international conferences – Attending or presenting research at academic or professional conferences held in other countries.
Licensing personal inventions – Licensing a patent or invention developed outside of UAF to a company or organization for commercial use.
Consulting on patent development – Providing expertise to an external company on developing or managing patents.
Starting a business based on personal IP – Founding a company that uses intellectual property you have developed, such as patents, trademarks, or copyrights.
Royalty agreements from IP – Receiving royalties or compensation for intellectual property (like a patent or software) you created independently of your UAF work.
Collaborating on IP with a non-UAF entity – Working with a company or organization outside of UAF to co-develop or co-own intellectual property.
Owning stock in a company – Holding shares in a company that is not affiliated with UAF, particularly if the company is involved in areas related to your research.
Holding stock options in a startup – Owning options to purchase stock in a company, especially one that is developing products or technologies related to your academic work.
Investing in a privately held company – Owning equity in a private company, such as a tech startup, that is working in a field relevant to your research.
Co-owning a company with research interests – Having a financial stake in a company that is based on intellectual property or
research similar to your UAF work.
Receiving payment for consulting – Getting paid for providing expert advice or services to a company or organization outside of UAF.
Receiving a travel reimbursement – Being reimbursed for travel expenses incurred while attending or presenting at an event or conference organized by an external entity.
Receiving a grant from an external organization – Being awarded a research or project grant from a non-UAF organization, such as a corporation or foundation.
Receiving a loan from an outside entity – Taking a loan from a company or organization unrelated to UAF, particularly if
the terms may influence your academic or professional work.
A document that individuals, typically researchers, faculty, or staff, use to disclose any potential, apparent, or actual conflicts of interest related to their professional responsibilities at the university. This form is used to identify financial, personal, or institutional interests that could influence, or appear to influence, the individual’s research, teaching, or decision-making. The disclosure allows the university to assess the potential impact of these interests on objectivity and integrity and to implement appropriate management strategies or safeguards to mitigate any risks.
Refers to creations like patents or inventions that may generate financial benefits. When researchers or institutions have financial interests in IP, it can create a COI by influencing or appearing to influence research objectivity. Disclosure of such interests is crucial to maintaining research integrity.
Refers to professional or financial activities outside of an individual's university responsibilities, such as consulting, serving on boards, or holding a management role in a company. These activities can create a conflict if they interfere with or influence the individual's objectivity in their academic or research duties. Disclosure of outside activities is important to identify and manage potential COIs.
The intersection of two contradictory interests or commitments relating to an individual or an activity. The contradiction lies not in any specific behavior but in the underlying interests or commitments at hand.
An engagement or obligation that presumes the involvement or attention of an individual for specific purposes or time.
The traditional concept of a potential conflicting financial or personal benefit or gain (normally a monetary basis of concern).
Competing or overlapping demands or obligations to multiple programs, projects, or entities.
Competing personal and professional ideology or opinion as to a specific area of focus or effort.
The term "investigator" means the project director or principal investigator, co-investigators, and any person regardless of title or position who is responsible for the design, conduct, or reporting of the proposed or funded research or educational activity, which may include, for example, collaborators or consultants.
Conflict of Interest Process Review RACI
Conflict of Interest Review Process Workflow
The Office of Research Integrity at the University of Alaska Fairbanks has arranged access for all researchers, staff, and students to the Collaborative Institutional Training Initiative (CITI) Conflict of Interest course material. This program provides the opportunity for UAF personnel engaged in research activities to formally document their knowledge and understanding of basic ethical principles related to conflicts of interest in research..
Register:
- Visit the CITI Homepage.
- Select the "New Users: Register Here" link.
- Select the "University of Alaska Fairbanks" as your Participating Institution and complete the rest of the registration information.
Select your course(s):
- When prompted to select a curriculum, in Question 1 select "Not at this time."
Then in Question 6, under ‘Conflicts of Interest (COI) - Optional for researchers’ select ‘Yes’. Scroll to the bottom of the ‘Select Curriculum’ page and click ‘Submit’.
* if you have previously taken a CITI approved course, your training may cover this requirement. If you are unsure whether a course you have taken is approved, please contact the ORI. - The Active Courses will then display the course. Click “Start Now” to begin. You do not have to finish all modules at one time; CITI saves your scores each time you submit answers so you can log out and resume later. *You must receive a score of 100% on each module to pass.
Contact the Office of Research Integrity (907-474-7800) or e-mail the Research Integrity
Administrator at uaf-ori@alaska.edu if you have any questions or problems registering.
- R04.10.030. Conflict of Interest (Regulation)
- University of Michigan https://research-compliance.umich.edu/conflict-interest-coi
- Common Form for Biographical Sketch
- Common Form for Current and Pending (Other) Support
- CURRENT AND PENDING (OTHER) SUPPORT COMMON FORM
- Board of Regents’ Conflict of Interest Policy
- Conflict of Interest, 2 CFR § 200.112 (2024).
