3 rd Party Entity A. Individual Financial Interests B. Spouse Financial Interests C. Dep. Children Financial Interests D. Collective (A+B+C) E. Significant.
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Presentation on theme: "3 rd Party Entity A. Individual Financial Interests B. Spouse Financial Interests C. Dep. Children Financial Interests D. Collective (A+B+C) E. Significant."— Presentation transcript:
3 rd Party Entity A. Individual Financial Interests B. Spouse Financial Interests C. Dep. Children Financial Interests D. Collective (A+B+C) E. Significant Financial Interest in any Column A-D? If yes, proceed to next chart Company X$ 8,000 royalties (salary) $ 3,000 salary none$ 11,000 compensation 1.> $10,000 Equity 2. > 5% equity if private 3. at least 0.5% equity if public? 4. > $10,000 compensation over a 12 month period? 5. Intellectual Property Rights? □ no Company Y8% ownership interest none 8% ownership interest 1.> $10,000 Equity 2. > 5% equity if private 3. at least 0.5% equity if public? 4. > $10,000 compensation over a 12 month period? 5. Intellectual Property Rights? □ no 3 rd Party Entity Could the Significant Financial Interest Reasonably Appear to Others to be Related to My Work? Yes in both columns? Company X SFI? □ no 1. Connected to my research in any way? (current or future?) 2. Do I make decisions at work that involve this company? 3. Can I benefit financially by committing Notre Dame resources to this company? □ no If yes, required to disclose Company Y SFI? □ no 1. Connected to my research in any way? (current or future?) 2. Do I make decisions at work that involve this company? 3. Can I benefit financially by committing Notre Dame resources to this company? □ yes If yes, required to disclose Disclosure Guide Conflict of Interest 1. Financial Interests in a Third Party Entity Do you, your spouse and/or dependent children, individually or collectively, have any of the following significant financial interests that are, or could reasonably appear to be, related to your work at the University: ● Equity or similar financial interest in a third party entity that exceeds $10,000 in value or that represents more than a 5% ownership interest in any privately held enterprise or entity or at least a 0.5% ownership interest in a publicly traded company? ● Salary, royalties, or similar compensation that exceed, or are expected to exceed, $10,000 in a twelve month period that are paid by or originate from a third party entity? ● Ownership interest in any intellectual property rights? Guided by federal requirements, the first question identifies thresholds for when a financial interest constitutes a Significant Financial Interest (SFI) with a 3 rd party entity. The first chart below demonstrates how to evaluate whether or not an SFI exists. The second chart will help in determining whether or not the SFI is or could appear to others to be related to your work at the University. When an SFI and a relation to your work exists with an outside entity, the development of a management plan is required to manage, reduce or eliminate the conflict. □ yes □ no □ yes
Disclosure Guide Conflict of Interest 2. Positions Held in a Third Party Entity Do you hold a management position such as a board member, director, partner or trustee in any entity relating to your work at the University? Positions held in third party entities may not include a Significant Financial Interest, however, due to the nature of the relationship with the third party entity, the potential for or perception of a conflict of interest may exist. For example, if you serve as a director for an organization that also does business with the University and you have the opportunity to make decisions that involve this organization, your decisions could be viewed as biased toward fulfilling personal interests rather than the University’s. While merely holding a management or other position with an organization does not necessarily indicate a conflict, disclosure of the position provides an opportunity for the University to partner with you to prevent any questions regarding your professional integrity. 3.Relationships with any Sponsor, Vendor, Contractor Do you, any family member, or close friend, have a relationship with any sponsor, vendor, contractor, or business entity with which the University does, or is likely to do business, where you have an opportunity to influence the University’s decision-making related to that entity? While a position held with a third party entity is of a more formal nature, it is often the informal relationships an individual has with a third party entity that create the potential for or perception of a conflict of interests. It is important to consider not just your own relationships, but those of your family and close relation as well. An example of such a relationship is having a brother-in-law who owns an office supply store that does business with the University. Disclosing the relationship up front provides an opportunity to put mechanisms in place that reduce concerns about an individual’s objectivity, professional judgment or professional integrity. 4. Activities Involving Students and staff Do you receive non-University income from any activities that involve students, staff, or the use of Notre Dame property? As a member of the University Community, your paid involvement with other staff, students or non-job related use of ND property may also put you in a position of conflicting interests. For instance, if you own a consulting business and employ students from your department or area of expertise, the appearance of objectivity may be compromised when issuing grades for your student employees. Additionally, any non-University use of laboratory space, classroom, or other resources on campus by a University employee requires a contract with the University just as any other outside entity using the resources. 5. Any Other Activity Are you involved in any other activity that could result in a financial, personal, or professional benefit for you, a family member or close friend that: ● relates to any personal influence you may have in University operations or business decisions, or ● could appear to others to affect your decision-making and judgment in carrying out your work responsibilities? Consider the various activities and interests in which you, a family member or close relation, are involved and weigh whether or not they could be reasonably viewed by others to unfairly influence your decision-making in carrying out your University responsibilities. If in doubt as to whether certain activities or interests could be perceived as a conflict of interest, the disclosure process can provide an objective review to identify if there are any concerns and help prevent issues related to those concerns. For Additional Assistance Contact: Policy Specialist, Office of General Counsel email@example.com@nd.edu or 631-6411