Conflict of Interest and/or Commitment
Stony Brook University remains committed to the principles of academic freedom, free inquiry, and the open exchange of knowledge, which serve as the bedrock of scholarship and research. The University supports and encourages individuals to pursue and engage in external activities that promote the University's mission, contribute to professional fields, and enhance professional skills. In return, individuals are expected to fulfill their University obligations first and foremost, commensurate with their appointment requirements.
Campus Policy
Disclosure of External Interests and Commitments Policy
revised April 2022
Disclosure Obligations
Individuals have an obligation to avoid conflicts of interest and commitment when carrying out their external and University education, research, scholarship, or service responsibilities. All external relationships - both domestic and international - should be transparent and must be disclosed in a manner that is consistent with applicable requirements, including federal and state laws/regulations/agency guidance, as well as Stony Brook's own policies and procedures. Such disclosures must include activities that occur over summer/winter break months.
Who Must Disclose
The following individuals are required to disclose external interests and commitments:
- Salaried faculty
- Researchers (salaried and non-salaried)
- Executive/senior leadership
- Other personnel who advise on, negotiate or approve, on behalf of the University, transactions, arrangements or agreements with external parties involving the use of University resources.
What to Disclose
All financial, personal and professional interests, activities and relationships that you or an immediate family member have with any non-University entities that create, or could be perceived to create, a conflict of interest or commitment that:
- Might be reasonably perceived to be related to your institutional responsibilities; or
- May otherwise present a conflict of interest or conflict of commitment, or the perception of such a conflict, with your duties to the University.
The following is a non-exhaustive list of the types of external interests and commitments of individuals and their immediate family members, whether located in the U.S. or outside of the U.S., that must be disclosed:
- External paid and unpaid positions/obligations at institutions other than Stony Brook, including: current relationships, relationships that occurred during the previous 12 months, and any anticipated future relationships, whether located in the U.S. or outside of the U.S.
- External resources/support provided by entities other than Stony Brook or Research Foundation for SUNY (e.g.: payments or remunerations, provision of or support for laboratory or other facilities, gifts, equity holdings or ownership, and sponsored travel).
- Relationship with an external organization (e.g.: research, consulting, sponsored travel, equity in external company, etc.).
- Intellectual property rights and interests.
Foreign Talent Recruitment Program Disclosure Requirements
Annual attestation about current participation, or participation in the previous twelve (12) months, in a Foreign Talent Recruitment Program.How to Disclose
All those who must disclose (as defined above) are required to do the following:
Create a Disclosure Profile: Create a Disclosure Profile through the myResearch portal.
Maintain a Disclosure Profile: Maintain their Disclosure Profile by modifying their profile to account for new or anticipated external interests and/or commitments within 30 days of acquiring knowledge of such external interests and/or commitments.
Annual Disclosure Profile Certification: Certify to the completeness and accuracy of their profile at least annually which includes during the annual disclosure period.
Note: This Annual Disclosure Profile Certification is separate from the annual NYS Financial Disclosure Statement that is submitted to the NYS Joint Commission on Public Ethics (JCOPE) by filers. Some individuals may be required to submit under both disclosure processes.
When to Disclose
The annual filing period is May 1 to May 31 and modifications must be made as necessary year-round.
Special Instructions for those not listed under "Who Must Disclose"
RF employees not required to complete an Annual Disclosure Certification should report any potential or real conflict of interests or commitments to Susan Gasparo, Conflicts of Interest Administrator at ovpr_coi_admin@stonybrook.edu or susan.gasparo@stonybrook.edu.
NYS employees not required to complete an Annual Disclosure Profile Certification or a JCOPE filing who have questions as to whether or not they have a situation which would be deemed a conflict of interest or conflict of commitment should have a conversation first with their supervisor, and if further guidance is needed, Human Resources Services (HRS) may be contacted at HRS_Ethics@stonybrook.edu.
Newsletters
Frequently Asked questions
Visit the FAQs for more information
Training Requirements
All researchers (as defined in the Disclosure of External Interests & Commitments Policy) must complete the Conflict of Interest Training in CITI prior to engaging in any research and at least every four years.
In addition, researchers are required to complete training immediately under the following circumstances:
- SBU COI policies change in a manner that affects Investigator requirements
- A researcher is new to SBU
- SBU finds a researcher noncompliant with Institution's policy or management plan.
Sponsor Agency Regulations
U.S. Department of Health and Human Services, Public Health Service regulations
- Responsibility of Applicants for Promoting Objectivity in Research (42 CFR Part 50, Subpart F)
- Responsible Prospective Contractors (45 CFR Part 94)
Note: Some Non-PHS agencies have adopted the DHHS regulations
Department of Energy Interim Conflict of Interest Policy Requirements for Financial Assistance
National Science Foundation Grant Policy Manual
National Aeronautics and Space Administration Policy (Effective 12/1/23 for new and amended awards)
Resources
Examples
- Conflict of Interest Scenarios
- Managed Conflict of Interest
- Management Plans
- Publication Disclosure Statements for Conflict of Interest
Related Policies
Guidelines for Faculty Start Ups. Agreements must be in place between a student and faculty member before student participation in a startup begins.
Provost's Office: Outside Consulting Work
Business Relationships & Financial Transactions
SUNY Policy 6001: Conflict of Interest
SUNY Research Foundation Conflict of Interest Policy