XX.E.1   Conflict of Interest and Conflict of Commitment

Yale is committed to ensuring that the research, consultation, and other activities of faculty and non-faculty employees are conducted properly and consistently with the principles of openness, trust, and free inquiry that are fundamental to the autonomy and well-being of a university and with the responsible management of the University's business. Toward that end and consistent with federal regulations, Yale has formulated a policy and procedures to identify and address potential, actual, and apparent conflicts of commitment and conflicts of interest. The text of the policy and procedures can be viewed on the Provost Office Web site. The fundamental premise of this policy is that each member of the Yale community has an obligation to act in the best interests of the University, and must not let outside activities or outside financial interests interfere with that obligation.

A conflict of commitment occurs when the commitment to external activities of a faculty or staff member adversely affects his or her capacity to meet University responsibilities. This form of conflict is easily defined and recognized since it involves a perceptible reduction of the individual's time and energy devoted to University activities. Obligations to the University are not discharged solely by teaching classes; individuals must be available to their students outside the classroom, participate on committees and in other University activities, supervise graduate students and postdoctoral trainees, and make constant progress in research programs. Any relationship with an outside organization that requires frequent or prolonged absence from Yale represents a conflict of commitment that must be avoided.

A conflict of interest exists when an individual has an external economic or other personal interest that affects or provides an incentive to affect the individual's conduct of his or her University activities. Conflicts of interest can arise naturally from an individual's engagement with the world outside the University, and the mere existence of a conflict of interest does not necessarily imply wrongdoing on anyone's part. When conflicts of interest do arise, however, they must be recognized, disclosed, and either managed, reduced, or eliminated. Even when no conflict actually exists, the appearance of conflict of interest may be present. Such apparent conflicts can do as much damage as actual ones, undermining the credibility of research, clinical care, scholarship, or University financial decisions, and must be avoided.

The Policy on Conflict of Interest and Conflict of Commitment requires that all faculty members employed more than half-time at the University, all faculty members who hold administrative positions, and all faculty members responsible for the design, conduct, or reporting of research at the University, even if employed half-time or less , submit an annual Conflict of Interest/Commitment Disclosure Form . All such faculty must update the form whenever a material change has occurred and, whenever possible, disclose expected changes or newly anticipated financial or outside interests before they occur. Faculty new to Yale should complete the form as soon as possible after their arrival. The Provost's Committee on Conflict of Interest and Conflict of Commitment (the Committee) is charged with reviewing disclosure forms and making recommendations to the Provost with respect to any actions required to manage, reduce, or eliminate conflicts.

An investigator may not apply for a grant or contract until he or she has completed and submitted an up-to-date disclosure form; likewise a grant or contract award cannot be established until the required disclosures have been made and reviewed, and a determination reached either that no conflict of interest exists or that an identified conflict has been appropriately managed, reduced, or eliminated. In addition to the annual disclosure form that is submitted to the Committee, investigators conducting research involving human participants may be subject to supplemental disclosure requirements as outlined in the policies of the cognizant Institutional Review Board.

Yale is committed to ensuring that the research, consultation, and other activities of faculty and non-faculty employees are conducted properly and consistently with the principles of openness, trust, and free inquiry that are fundamental to the autonomy and well-being of a university and with the responsible management of the University's business. Toward that end and consistent with federal regulations, Yale has formulated a policy and procedures to identify and address potential, actual, and apparent conflicts of commitment and conflicts of interest. The text of the policy and procedures can be viewed on the Provost Office Web site. The fundamental premise of this policy is that each member of the Yale community has an obligation to act in the best interests of the University, and must not let outside activities or outside financial interests interfere with that obligation.

A conflict of commitment occurs when the commitment to external activities of a faculty or staff member adversely affects his or her capacity to meet University responsibilities. This form of conflict is easily defined and recognized since it involves a perceptible reduction of the individual's time and energy devoted to University activities. Obligations to the University are not discharged solely by teaching classes; individuals must be available to their students outside the classroom, participate on committees and in other University activities, supervise graduate students and postdoctoral trainees, and make constant progress in research programs. Any relationship with an outside organization that requires frequent or prolonged absence from Yale represents a conflict of commitment that must be avoided.

A conflict of interest exists when an individual has an external economic or other personal interest that affects or provides an incentive to affect the individual's conduct of his or her University activities. Conflicts of interest can arise naturally from an individual's engagement with the world outside the University, and the mere existence of a conflict of interest does not necessarily imply wrongdoing on anyone's part. When conflicts of interest do arise, however, they must be recognized, disclosed, and either managed, reduced, or eliminated. Even when no conflict actually exists, the appearance of conflict of interest may be present. Such apparent conflicts can do as much damage as actual ones, undermining the credibility of research, clinical care, scholarship, or University financial decisions, and must be avoided.

The Policy on Conflict of Interest and Conflict of Commitment requires that all faculty members employed more than half-time at the University, all faculty members who hold administrative positions, and all faculty members responsible for the design, conduct, or reporting of research at the University, even if employed half-time or less , submit an annual Conflict of Interest/Commitment Disclosure Form . All such faculty must update the form whenever a material change has occurred and, whenever possible, disclose expected changes or newly anticipated financial or outside interests before they occur. Faculty new to Yale should complete the form as soon as possible after their arrival. The Provost's Committee on Conflict of Interest and Conflict of Commitment (the Committee) is charged with reviewing disclosure forms and making recommendations to the Provost with respect to any actions required to manage, reduce, or eliminate conflicts.

An investigator may not apply for a grant or contract until he or she has completed and submitted an up-to-date disclosure form; likewise a grant or contract award cannot be established until the required disclosures have been made and reviewed, and a determination reached either that no conflict of interest exists or that an identified conflict has been appropriately managed, reduced, or eliminated. In addition to the annual disclosure form that is submitted to the Committee, investigators conducting research involving human participants may be subject to supplemental disclosure requirements as outlined in the policies of the cognizant Institutional Review Board.