Importance of Disclosing Potential Conflicts of Interest

Conflicts of interest (COI) have been the focus of many news stories in Medicine, Industry, and, more recently, Higher Education. Unmanaged COI's can result in consequences ranging from damaged reputation to penalties and fines, both for the individual who has the conflict and the institution for whom s/he works. Caltech has a formalized policy on the disclosure and management of conflicts of interest and conflicts of commitment to ensure the integrity of individuals and the Institute in both business and research at the Institute.

What is a COI? As stated in our Conflict of Interest Policy: "An individual conflict of interest is a situation that may compromise an individual's professional judgment in carrying out Institute business due to an external relationship that directly or indirectly affects the interest of the individual or an immediate family member. Each situation that presents a potential for conflict of interest must be fully disclosed to Caltech, and managed or eliminated before moving forward. Conflicts of interest also include conflicts of commitment which are situations in which external activities, either paid or unpaid, interfere with an employee's primary obligation and commitment to Caltech."

Pursuant to our Policy, at least once a year, all Caltech personnel must disclose certain financial interests, gifts, and outside commitments that may overlap with, be related to, or may be perceived as potentially impacting their work for Caltech. Once disclosed, supervisors, division administrators or division chairs evaluate the interests and commitments and determine whether or not the individual has a conflict of interest or commitment exists. If a conflict is identified, individuals work with their respective supervisor, division administrator or chair, human resources, and/or the Office of Research Compliance to find a way to mitigate or eliminate the conflict. The process seems straightforward but can become complicated depending on the nature of the conflict.

So what should you disclose? Can you disclose too much? The short answer is to err on the side of caution and disclose all interests, relationships or commitments that are related to, overlap with, or may be perceived as potentially impacting your work for Caltech. Transparency is your friend! If you are uncertain whether or not something should be disclosed, talk with your supervisor, division administrator or chair.

When should you disclose? Well, it depends. You are required to disclose at least annually, in June. Failure to do this in June can result in delays to your annual salary increase and/or research proposal submission. You are also required to disclose during the year if 1) you acquire a new financial interest or gift or 2) you wish to work or consult for an outside entity. If you acquire a new financial interest or gift that is covered under the policy, you must disclose within 30 days of acquiring the interest. If you are a staff member or postdoc and want to work or consult for an outside entity, you must file a new disclosure and complete an Outside Activity Request Form and have it approved beforebeginning the work. If you are a faculty member and wish to work for or consult for an outside entity and the work will overlap with your research at or work for Caltech, you must file a new disclosure.

Where do I go if I have questions? Non-research staff should approach their supervisors or Human Resources. Research personnel (staff, visitors, postdocs) should approach the Division Administrator or the Office of Research Compliance and faculty should approach the Division Chair or the Office of Research Compliance.

Who cares? We all should. Even appearances of conflict of interest or commitment can result in a damaged reputation for the individual or the institute. Actual conflicts of interest or commitment can compromise the integrity of research or result in serious financial consequences. While these consequences could be significant, if everyone follows the established processes, it will ensure the integrity and reputation of the Institute and all of its faculty and staff.