Conflict of Interest

The term “Conflict of Interest” refers to situations in which financial or other personal considerations may directly and significantly affect, or have the appearance of directly and significantly affecting, a person’s judgment in exercising their University responsibilities. Such situations do not necessarily imply wrong-doing or inappropriate activities. However, it is important that these situations are disclosed and appropriately managed.

The term “Conflict of Commitment” relates to the distribution of effort between one’s University appointment and one’s outside activities. The latter may include professionally related activities such as involvement with professional societies, participation on review panels, and external professional activities for pay. These activities often promote professional development.

UNC Charlotte affiliated personnel

University Policy 101.24, Conflicts of Interest and Commitment, applies to:

• All full-time, part-time and adjunct members of the faculty
• All non-faculty EHRA staff
• Designated SHRA staff (see COI Policy for details)
• Research personnel involved in the design, conduct, or reporting of a funded research project, contract, sub-contract, or other agreement.

Disclosures must include the Financial Interests of immediate family members (i.e., spouse and dependent children).

Individuals responsible for the design, conduct, or reporting of a Public Health Service (PHS) funded research project are also required to disclose sponsored travel and paid authorships.

Subrecipients and Independent Contractors

Individuals meeting the definition of Investigator (i.e. responsible for the design, conduct, or reporting of a funded research project) may include non-university personnel, such as subcontractor employees, collaborators, or consultants/independent contractors. If the project is NSF or PHS funded and the subrecipient’s home institution does not have a compliant COI Policy, then that subrecipient must agree in writing to comply with the UNC Charlotte COI Policy. Independent Contractors that meet the definition of Investigator are always subject to UNC Charlotte’s COI Policy.

Note: Phase I Small Business Innovation Research (SBIR) or Phase I Small Business Technology Transfer Research (STTR) grants are excluded from the PHS COI regulations. However, Phases II & III are not excluded from the PHS COI regulations.

• External Professional Activities for Pay (EPAP)
  • Payment includes all types of remuneration plus stocks, stock options, or bonds.
  • EPAP often overlap with many of the below reportable activities, and require 10 days’ advance notice for supervisor approval.
• Publicly Traded Companies
  • Ownership of stock, options, etc. from any entity during the preceding 12 months, for you and your family members that appears to be related to your institutional responsibilities.
  • Note: Investments in which you do not directly control investment decisions, such as mutual funds or retirement accounts, do not need to be disclosed.
• Privately Held or Nonprofit Companies
  • Any ownership or equity interest from any entity whose stock is not publicly traded, by you and your family members that appears to be related to your institutional responsibilities.
• Other Financial Interests
  • Any payment that is related to your professional responsibilities at the university.  Examples would include: private consulting, serving on a board of directors, speaking engagement, etc.
  • Royalties from textbooks or other scholarly works
• Intellectual Property Rights
  • Intellectual Property (IP) in which you or your family members, have an existing or proposed licensing interest.
  • IP rights held (or in negotiation) for a pending or issued patent in which you or your family members are listed as inventors.
  • The Patent Policy should be referenced for additional information.
• External Roles
  • Paid or unpaid affilations and positions of influence, by you or your family members, with an entity in which the interests of the entity appear related to your institutional responsibilities (i.e. CEO, President, Scientific Advisory Board member, etc.).
• Student Involvement or Supervisory Roles
  • Situations in which an activity could create a potential conflict of interest or commitment with respect to a faculty member’s mentorship responsibility.
  • Textbook or course material selection that results in receipt of royalties or other potential financial conflicts of interest. The Textbooks and Instructional Materials Policy should be referenced for additional information. 
• Sponsored Travel
  • Reimbursed or sponsored travel whose aggregate value paid or reimbursed by any single entity meets or exceeds $250 in the prior twelve months, except travel that is reimbursed or sponsored by a Federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

• Annually (October 1st deadline)
• Upon assuming new University Employment Responsibilities
• Within thirty (30) days of discovering or acquiring any financial interests or activities for which disclosure is required
• With each sponsored research proposal submission, you will be prompted to update your current COI disclosure if applicable
• Ten days prior to engaging in an External Professional Activity for Pay (EPAP)

PLEASE NOTE: Grant proposals and MOUs (memoranda of understanding) may not be submitted and projects will not receive final approval until disclosure forms are received from ALL personnel listed on the project. Funding will not be released until any potential conflicts have been reviewed and managed, and training has been completed.

Niner Research is the University’s research management system; all Annual Conflict of Interest disclosures and External Professional Activity for Pay (EPAP) submissions are submitted in Niner Research. 

Annual Conflict of Interest Disclosure 

• Annual Conflict of Interest disclosures are required from all covered employees in Niner Research.
  • In addition to the Annual disclosure, covered employees must update their Annual Conflict of Interest disclosure within 30 days of any changes.  
• Covered employees include all EHRA staff, all faculty members (including part-time and adjunct faculty), and select SHRA roles.
  • This disclosure requirement applies to individuals on leave from the University if that leave is funded at least partially from University sources. Email COI-staff@charlotte.edu for additional information.  
• The deadline for submitting an Annual COI disclosure is October 1. Invitations to participate in the Annual COI disclosure campaign will be sent out on approximately September 1 of each year.  A new form is released yearly; early submissions may require an additional submission if the new form is not utilized. 

  EPAP (External Professional Activity for Pay) submissions

• External Professional Activities for Pay (EPAP) are also disclosed in Niner Research. 
• The Niner Research COI disclosure form integrates the EPAP form; in the Pre-screening page, eligible staff and faculty should carefully review question 4 to determine if an EPAP is present. 
• EHRA staff and faculty whose FTE is greater than or equal to 0.75 are subject to the External Professional Activities of Faculty and Other Professional Staff policy (UP 102.1) and must submit an EPAP form prior to participation.
  • SHRA staff should review the Secondary Employment Employees Subject to the State Human Resources Act policy (UP 103.3).
• EPAP submissions must be submitted no less than 10 days prior to participation in the activity.  
• A member of the discloser’s leadership will review and either approve or not approve the EPAP(s) submitted. The integrated Annual COI disclosure will then be sent to the COI Manager for review.  

All faculty members and non-administrative personnel listed on funded research projects are required to take training related to conflicts of interest. This training is now incorporated into the Niner Research COI disclosure form.