Conflict of Interest
Conflict of Interest Disclosure and Compliance Procedures for Researchers
Stony Brook University is committed to maintaining the integrity, objectivity, and public trust in research, scholarship, education, and service. Faculty, staff, and students are encouraged to engage in productive relationships with industry, government, nonprofit organizations, and other external entities that advance research, innovation, and the translation of discoveries for public benefit.
A Conflict of Interest (COI) may arise when an individual's financial or personal interests could affect—or appear to affect—the design, conduct, reporting, or oversight of research or other University responsibilities.
Most external financial relationships do not constitute a Conflict of Interest. The purpose of disclosure and institutional review is to promote transparency, identify situations that may require management, and protect the integrity of research while supporting appropriate collaborations, innovation, and technology transfer.
The Office of Research Security (ORS) administers the University's Conflict of Interest Program and works collaboratively with researchers, departments, the Office of Sponsored Programs, the Institutional Review Board, University leadership, and other offices to identify, review, and manage conflicts of interest, when appropriate.
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.
What Is a Conflict of Interest?
A Conflict of Interest exists when an individual's financial or personal interests could directly and significantly affect—or reasonably appear to affect—their professional judgment, research decisions, or University responsibilities.
Conflicts may arise from relationships with commercial entities, nonprofit organizations, government agencies, or other external organizations.
A Conflict of Interest does not imply wrongdoing. Many financial interests can be appropriately managed through disclosure, transparency, and, when necessary, implementation of a Conflict Management Plan.
Conflict Management
Most disclosed financial interests do not prevent participation in research or other University activities. The purpose of the University's Conflict of Interest Program is to identify situations that may require additional oversight or management while supporting responsible research, innovation, and collaboration.
When the University determines that a Conflict of Interest exists, ORS works collaboratively with the Researcher, academic leadership, the Conflict of Interest Committee (when appropriate), and other University offices to develop a Conflict Management Plan that is tailored to the specific circumstances.
Depending on the nature of the activity, management measures may include:
- disclosure to research team members, collaborators, sponsors, or research participants;
- independent oversight of research activities;
- modification of research roles or responsibilities;
- recusal from specific institutional decisions;
- monitoring of compliance with the Conflict Management Plan; or
- other measures appropriate to the activity.
Conflict Management Plans are designed to support research while protecting research integrity, objectivity, research participants, and public trust.
Learn more about Conflict Management Plans and Publication Disclosure Statements for Conflict of Interest
Common Activities That May Require Disclosure or Review
The following activities do not necessarily constitute a Conflict of Interest. Depending on the circumstances, however, they may require disclosure and institutional review.
Startup Companies
- Establishing or joining a startup company
- Founder or co-founder activities
- Equity ownership
- Executive or scientific leadership positions
Consulting and Professional Services
- Consulting
- Advisory board service
- Scientific advisory board participation
- Expert witness activities
- Honoraria and professional speaking engagements
Equity and Ownership Interests
- Stock ownership
- Stock options
- Ownership interests in privately held companies
- Equity received through technology licensing
Intellectual Property
- Royalties
- Licensing income
- Patent ownership
- Intellectual property rights
- Royalty-sharing agreements
Leadership Positions
- Officer positions
- Board of Directors
- Trustee positions
- Executive leadership roles
Sponsored or Reimbursed Travel
Certain sponsors and University policies require disclosure of sponsored or reimbursed travel related to an individual's institutional responsibilities.
Conflict of Interest vs. Conflict of Commitment
Although related, these concepts address different issues.
| Conflict of Interest | Conflict of Commitment |
|---|---|
| Financial or personal interests that could affect—or appear to affect—professional judgment or the objectivity of research or other institutional responsibilities. | External commitments that may interfere with a Researcher's ability to fulfill their University responsibilities. |
| Financial relationships with outside entities | Outside professional activities, appointments, or affiliations |
| Equity, royalties, consulting income, honoraria | Time, effort, and competing professional commitments |
| Potential for bias in research or institutional decision-making | Ability to fulfill University responsibilities |
Some activities may involve both a Conflict of Interest and a Conflict of Commitment and may require review under both institutional processes.
Planning an External Activity? Contact ORS Early
Many external professional activities support research, innovation, and technology transfer. Early consultation with ORS can help identify disclosure requirements, sponsor obligations, and appropriate conflict management strategies before research activities begin.
Researchers are encouraged to contact ORS if they are considering activities such as:
- establishing or joining a startup company related to University research;
- accepting equity or an ownership interest in a company related to their research or institutional responsibilities;
- consulting for an entity that sponsors, supports, or may reasonably benefit from their research;
- serving as an officer, director, trustee, or member of a scientific or medical advisory board;
- licensing or commercializing University-developed technology;
- receiving royalties or other financial interests related to their research;
- conducting human subjects research involving an entity with which they have a financial relationship; or
- engaging in any activity where an external financial interest or commitment could reasonably affect—or appear to affect—their research or other institutional responsibilities.
Early consultation allows ORS to:
- identify applicable disclosure requirements;
- determine whether sponsor-specific requirements apply;
- coordinate review with other University offices, when appropriate;
- develop conflict management strategies before research begins; and
- help avoid delays during proposal submission, award acceptance, IRB review, or technology commercialization.
How ORS Can Assist
ORS works collaboratively with researchers, departments, and University partners to:
- explain University and sponsor disclosure requirements;
- evaluate whether a disclosed relationship requires additional review;
- coordinate review with the Conflict of Interest Committee and other University offices, as appropriate;
- assist with sponsor-specific disclosure and reporting requirements;
- develop Conflict Management Plans when appropriate; and
- support compliance with University policy and applicable federal regulations.
Most external financial relationships can be appropriately managed through disclosure, transparency, and, when necessary, implementation of a Conflict Management Plan.
Frequently Asked Questions
Visit the Frequently Asked Questions page for answers to common questions about:
- consulting activities;
- startup companies;
- equity interests;
- disclosure requirements;
- sponsor requirements;
- Conflict Management Plans; and
- annual disclosure responsibilities.
Related Policies and Resources
University Policies and Guidance
- Disclosure of External Interests & Commitments Policy
- Provost's Office – Approval Process for Faculty Members Offered Appointments at Foreign and Domestic Institutions
- Provost's Office – Outside Consulting Work
- Policy on International Engagements
- Guidelines for Faculty Startup Companies (Agreements must be in place between a faculty member and student before student participation in a startup company begins.)
Federal Sponsor Guidance
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)
Several non-PHS federal agencies have adopted or incorporated these regulations into their own financial conflict of interest requirements.
Other Federal Agencies
- 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)