Conflicts of Interest and Commitment (Excluding Financial Conflict of

CORNELL UNIVERSITY

POLICY LIBRARY

POLICY 4.14

Volume: 4, Governance/Legal

Chapter: 14, Conflicts of Interest

and Commitment

Responsible Executive: Provosts/

University Counsel

Responsible Office: Provosts/

University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31, 2020

Conflicts of Interest and

Commitment (Excluding

Financial Conflict of Interest

Related to Research)

OLICY

TATEMENT

All members of the Cornell University community are expected to conduct the affairs

of the university in a manner consistent with their primary commitments to the

university, and the performance of their professional responsibilities must be free

from real or apparent bias motivated by self-interest. This policy, and the

complementary University Policy 1.7, Financial Conflict of Interest Related to

Research, sets forth the principles and procedures to identify, report, review, and

manage real and apparent conflicts of commitment and conflicts of interest.

EASON FOR

OLICY

The university recognizes that the quality of teaching, research, extension service,

and the administration of university programs may be enhanced when members of

the Cornell University community participate in extramural activities. This policy

establishes the principles and procedures to assure that individuals’ primary

commitments to the university and the objective performance of their professional

responsibilities are not adversely affected by external commitments and financial

interests.

NTITIES

FFECTED BY THIS

OLICY

‒ All units of the university

WHO SHOULD READ THIS POLICY

‒ Trustees, faculty, and staff

DDRESS FOR THIS

OLICY

‒ This policy: www.dfa.cornell.edu/policy/policies/conflicts-interest-and-

commitment-excluding-financial-conflict-interest-related

‒ University Policy Office: www.policy.cornell.edu

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ONTENTS

Policy Statement _______________________________________________________ 1

Reason for Policy ______________________________________________________ 1

Entities Affected by this Policy __________________________________________ 1

Who Should Read this Policy ____________________________________________ 1

Web Address for this Policy _____________________________________________ 1

Related Resources ______________________________________________________ 4

Contacts ______________________________________________________________ 5

Definitions ____________________________________________________________ 6

Responsibilities ________________________________________________________ 8

Principles _____________________________________________________________ 9

Overview ______________________________________________________ 9

Conflicts of Interest _____________________________________________ 9

Financial Conflicts of Interest Related to Research ___________________ 10

Conflicts of Commitment ________________________________________ 11

Community, Civic, and Governmental Activities ____________________ 12

Procedures ____________________________________________________________ 13

Trustees, Overseers, Officers of the Corporation, and Other Senior Administrators

______________________________________________________________ 13

Deans, Directors, and Academic Unit Heads ________________________ 14

Academic and Nonacademic Staff Members Involved in Research _____ 14

All Other Academic Staff ________________________________________ 15

All Other Nonacademic Staff _____________________________________ 15

Managing Reporting-Line Conflicts (Including Avoiding Nepotism) __ 16

Appeals _______________________________________________________ 17

Sanctions for Non-Compliance ___________________________________ 17

Reporting Suspected Conflicts of Others ___________________________ 18

University Conflicts Committee (UCC) ____________________________ 18

Additional Procedures Specific To Weill Cornell Campus Units _____________ 20

Conflicts Management Office (CMO) ______________________________ 20

Conflicts Advisory Panel ________________________________________ 20

Conflict Disclosure ______________________________________________ 21

Travel Disclosure _______________________________________________ 21

Sanctions and Disciplinary Actions ________________________________ 24

Right to Appeal ________________________________________________ 24

Industry Relationships __________________________________________ 24

Frequently Asked Questions (FAQ) Regarding WCMC Conflicts Survey 31

Annual Disclosure Review Process ________________________________ 35

Appendix A: Examples and Commentary _________________________________ 36

Conflicts of Interest _____________________________________________ 36

Conflicts of Commitment ________________________________________ 38

Appendix B: Community, Civic, and Governmental Activities _______________ 40

Community, Civic, and Municipal Activities _______________________ 40

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: June 16, 2016

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ONTENTS

continued

Appendix C: START-UP NY _____________________________________________ 41

Introduction ___________________________________________________ 41

Section 220.20 Conflict of Interest Guidelines _______________________ 41

Index _________________________________________________________________ 43

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ELATED

ESOURCES

University Policies and Documents Applicable to All Units of the University

University Policy 1.7 Financial Conflict of Interest Related to Research

University Policy 3.6, Financial Irregularities

University Policy 3.25, Procurement of Goods and Services

University Policy 4.6, Standards of Ethical Conduct

University Policy 6.3, Consensual Relationships

Cornell Conflict of Interest website, maintained by the Office of Research Integrity and Assurance

Guidelines for Addressing Potential Conflicts of Interest and Commitment in Faculty/Staff Involvement in

Startup Companies

University Policies and Documents Applicable to Only Ithaca Campus Units

University Policy 3.11, Effort Planning and Confirmation

University Policy 6.9, Time Away From Work (Excluding Academic and Bargaining Unit Staff)

University Policy 6.11.3, Employee Discipline (Excluding Academic and Bargaining Unit Staff)

Bylaws of the Board of Trustees

Dismissal/Suspension Policy for Faculty Members

Human Resources Policy 6.11.4, Staff Complaint and Grievance Procedure

Human Resources Policy 6.13.1, Conflict of Commitment: Dual Appointment

The Faculty Handbook, Chapter 5: Academic Policies and Responsibilities, Conflicts of Interest and

Conflicts of Commitment; Consulting

University Policies and Documents Applicable to Only Weill Cornell Campus Units

Weill Cornell Medical College Academic Handbook

Employee Complaint and Grievance Procedure, Weill Cornell Medical College

Weill Research Gateway Job Aid: Conflicts of Interest Reporting

Annual Conflicts Survey: Quick Reference Guide

New York Presbyterian Code of Conduct

External Resources

START-UP NY Regulations, Section 220.20 (PDF) (see the Appendix C section of this document)

NIH Financial Conflicts of Interest Regulations

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ONTACTS

Direct any general questions about this policy to your college or unit administrative

office. If you have questions about specific issues, contact the following offices.

Ithaca Campus Units

Subject Contact Telephone Email/Web Address

Policy Clarification and

Interpretation

Office of the Provost (607) 255-2364 provost@cornell.edu

www.cornell.edu/provost/

University Counsel (607) 255-5124

Federal and State Laws

and Regulations on

Financial Conflicts of

Interest

Office of Research Integrity and

Assurance

(607) 255-6439 www.oria.cornell.edu

Reporting Suspected

Conflicts of Others

Immediate supervisor Unit-specific

University Audit Office (607) 255-9300

Cornell Hotline (866) 384-4277 (toll-free) www.hotline.cornell.edu

Weill Cornell Campus Units

Subject Contact Telephone Email/Web Address

Conflicts of Interest Policy

and Conflicts Survey

Conflicts Management Office (646) 962-8200 conflicts@med.cornell.edu

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

EFINITIONS

These definitions apply to terms as they are used in this policy.

Academic Staff Member

Any instructional or research staff member listed in Article XVII,

Section 1. of the Cornell University Bylaws (see Related Documents).

Apparent Conflict of Interest

A situation that arises when there is a reasonable concern, which an

informed person is likely to have, that the opportunity for personal

gain could compromise or influence the performance of an individual’s

professional responsibilities.

Associate

A person, trust, organization, or enterprise (of a business nature or

otherwise) with respect to which the individual or any member of his

or her family (1) is a director, officer, employee, member, partner, or

trustee, or (2) has a significant financial interest or any other interest

that enables him or her to exercise control or significantly influence

policy.

Community and Civic Activities

Elected or appointed service on local government councils, boards,

and commissions.

Conflict Management

Measures taken to address the risk of bias or the appearance of bias

when members of the university community have real or apparent

conflicts of interest.

Conflict of Commitment

A situation caused when an individual undertakes external

commitments that may burden or interfere with his or her primary

obligations and commitments to the university, even if the outside

activity is valuable to the university or contributes to professional

development and competence.

Conflict of Interest

A situation where an individual has the opportunity to influence the

university's business, administrative, academic, or other decisions in

ways that could lead to personal gain or advantage of any kind.

Consequential Personnel

Decision

A decision involving hiring, compensation (including annual merit

increases), duration of employment, work assignments, evaluations of

performance, promotion, termination, or another similar issue.

Disclose/Disclosure

To provide relevant information about an individual’s external

commitments and financial interests to parties inside and outside the

university to assure full awareness of potential conflicts and

institutional efforts to address them. Compare with Report, below.

External Commitment

An obligation or activity (e.g., management, employment, advisory, or

consulting role) that is not part of one’s primary commitments or

obligations to the university.

External Entity

An entity other than the university.

Family

An individual, and that individual’s spouse, domestic partner, parent,

sibling, child, or any other blood relative, if that other blood relative

resides in the same household.

Nonacademic Staff Member

An employee not included in the definition of Academic Staff Member,

above.

Officers of the Corporation

The president, provosts, chief financial officer, and university counsel

and secretary of the corporation, as defined in Article VI of the

university bylaws.

Other Senior Administrators

Vice provosts, vice presidents, chief investment officer, auditor,

treasurer, and controller.

Report [Ithaca] / Conflicts

Survey [WCMC]

To provide information to the university concerning one’s external

commitments and financial interests in accordance with this policy.

Significant Financial Interest

1. With regard to any publicly traded entity, a significant financial

interest exists if the value of any remuneration received from the

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

EFINITIONS

continued

entity in the twelve months preceding the disclosure and the

value of any equity interest in the entity as of the date of

disclosure, when aggregated, exceeds $5,000. For purposes of

this definition, remuneration includes salary and any payment for

services not otherwise identified as salary (e.g., consulting fees,

honoraria, paid authorship); equity interest includes any stock,

stock option, or other ownership interest, as determined through

reference to public prices or other reasonable measures of fair

market value.

2. With regard to any non-publicly traded entity, a significant

financial interest exists if the value of any remuneration received

from the entity in the twelve months preceding the disclosure,

when aggregated, exceeds $5,000, or when an individual or his

or her family holds any equity interest (e.g., stock, stock option,

or other ownership interest).

3. Related to intellectual property rights and interests (e.g.,

patents, copyrights), upon receipt of income related to such

rights and interests.

The term significant financial interest does not include the following

types of financial interests:



Salaries, royalties, or other remuneration paid by Cornell to an

individual, including intellectual property rights assigned to the

institution and agreements to share in royalties related to such

rights.



Income from investment vehicles, such as mutual funds and

retirement accounts, as long as the individual does not directly

control the investment decisions made in these vehicles.



Income from seminars, lectures, or teaching engagements

sponsored by, or income from service on advisory committees

or review panels for a federal, state, or local government

agency, a non-profit U.S. institution of higher education as

defined at 20 U.S.C. 1001(a), an academic teaching hospital, a

medical center, or a research institute that is affiliated with an

institution of higher education.



Any paid for or reimbursed travel determined by the Cornell to

not constitute a significant financial interest.

Unit

A department, research center, institute, program, business service or

financial transaction center, office, or other operating entity of the

university.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ESPONSIBILITIES

The major responsibilities each party has in connection with this policy are as

follows:

Advisory Committee Appointed

By the Provost

Consider appeals and recommend resolution to the provost.

Audit Committee of the Board

of Trustees

Oversee the administration of the university’s policies on conflicts of

interest.

Committee on Conflicts of

Interest of the Board of

Trustees

Manage conflicts for trustees, officers of the corporation, and other

senior administrators.

Conflicts Advisory Panel (CAP)

[WCMC]

Advise the dean of Weill Cornell Medical College (WCM), regarding

conflicts of interest and commitment (see Additional Procedures

Specific to Weill Cornell Medical College Campus Units in this

document).

Dean, Director, or Unit Head

Collect and retain reports of non-research-related external

commitments and interests.

Manage conflicts of individuals within the unit.

Provide the University Conflicts Committee (UCC) with such

summaries or reports of conflicts as it may require.

Individual

Discharge Cornell duties in a manner that is free from real or apparent

bias motivated by self-interest.

Report and manage conflict of interest and commitment in a manner

consistent with this policy.

Office of Research Integrity

and Assurance (ORIA) [Ithaca]

Office of Research Integrity

(ORI) [WCMC]

Collect and forward reports of potential conflicts of commitment to the

appropriate college, division, or other administrative unit.

Provost and Provost for

Medical Affairs

Manage conflicts of deans, directors, and unit heads.

When appropriate, appoint an advisory committee for appeals.

Make final and binding determinations under this policy regarding

appeals.

University Conflicts Committee

(UCC)

Maintain an ongoing awareness of college procedures, practices, and

standards, with a view toward assuring consistency.

Provide advice and recommendations to the provost on general

matters related to conflict of interest and conflict of commitment.

Report annually to the faculty and the president on matters within its

jurisdiction.

University Counsel

Advise on matters involving external commitments and financial

interests of trustees, officers of the corporation and other senior

administrators.

Where appropriate, consult with the Committee on Conflicts of

Interest of the board of trustees.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

RINCIPLES

Overview

All members of the Cornell University community are expected to promote the best

interests of the institution in the conduct of their Cornell responsibilities. Individuals

who accept full-time appointments must maintain a primary commitment to the

university, and must discharge their Cornell duties free from real or apparent bias

motivated by self-interest. The university recognizes that the quality of teaching,

research, extension, and clinical service, and administration of university programs is

enhanced when individuals participate in extramural activities. This policy, and the

complementary policy on Financial Conflict of Interest Related to Research, sets forth

the general principles and procedures to identify, review, manage, and disclose real

and apparent conflicts of commitment and conflicts of interest.

Individuals are expected to evaluate and arrange their external interests and

commitments in order to avoid compromising their ability to carry out their primary

obligations to the university. In the first instance, conflicts should be avoided or

resolved through the exercise of individual judgment or discretion. Full disclosure of

the circumstances surrounding a real or potential conflict should be made prior to

making the commitment or initiating the activity that poses the possible conflict.

Disclosure shall be sufficiently detailed to permit an accurate and objective

evaluation.

Conflicts of Interest

An individual is considered to have a conflict of interest when he or she, a member of

his or her family, or an associate (to his or her present knowledge) either (1) has an

existing or potential significant financial interest or other material interest or

relationship that impairs or might appear to impair the individual's independence

and objectivity in the discharge of his or her responsibilities to the university; or (2)

may receive a financial or other material benefit from information confidential to the

university.

Typically, a conflict of interest may arise when an individual has the opportunity to

influence the university's business, administrative, academic, or other decisions in

ways that could lead to personal gain or advantage of any kind.

Upon full reporting, the university may approve a transaction or affiliation, provided

that the conflict can be managed. In many cases, the conflict can be managed through

disclosure. In some cases, the individual may be required to report on the conflict

annually. The university will disapprove the transaction or affiliation if a conflict of

interest is involved that cannot be managed.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

RINCIPLES

continued

Business Ventures

An individual involved in a business venture as owner, operator, or major investor

must be alert to the possibility that a conflict may arise. If the entity does no business

with the university, only the area of conflict of commitment is likely to be involved.

If the entity does business with the university, or might do business with the

university, whether in a research or non-research context, the individual is expected

to report that fact. Generally, there is the potential for a real or apparent conflict of

interest where an opportunity exists for the individual’s interest in the business to

influence the university or the individual’s professional decisions.

Contracting

An employee may not review, approve, or administratively control a contract when

the contract is between the university and a company in which the employee has a

significant financial interest, or when the contract is with a member of the employee's

family, or when a member of the employee's family is an employee of the contractor

and directly involved with activities included under the contract or has a significant

financial interest in the contractor.

Gifts

No gifts or accommodations of any nature may be accepted by any individual when

to do so could possibly place that individual in a prejudicial or embarrassing

position, interfere in any way with the impartial discharge of duties to the university,

or reflect adversely on that individual’s integrity or that of the university. For more

information, see University Policy 4.6, Standards of Ethical Conduct and University

Policy 3.25, Procurement of Goods and Services.

Reporting-Line Conflicts (Including Nepotism)

The university requires that a person not supervise or be in the direct line of

authority over a family member, or someone with whom they are in a consensual

relationship, without the written approval of the responsible university official.

Such situations must be disclosed and managed (see “Managing Reporting-Line

Conflicts (Including Avoiding Nepotism)”).

Financial Conflicts of

Interest Related to

Research

The university addresses financial conflicts of interest arising from the design,

conduct, reporting, or direct administration of research (research-related conflicts)

separately from those that do not (non-research-related conflicts). Individuals

involved in the design, conduct, reporting, or direct administration of research must

also read carefully and comply with University Policy 1.7, Financial Conflict of

Interest Related to Research (see the Related Resources section of this policy).

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

RINCIPLES

continued

Conflicts of

Commitment

For All Members of the Cornell University Community

A conflict of commitment arises when an individual undertakes external

commitments that may burden or interfere with primary obligations and

commitments to Cornell. See appendix A for illustrative examples.

Trustees, Officers of the Corporation, and Other Senior Administrators

Trustees, officers of the corporation, and other senior administrators are fiduciaries,

owe special duties of care and loyalty to the institution as a whole, and must keep the

university's interests paramount to all others.

Academic Staff

An academic staff member who accepts a full-time appointment has a primary

commitment that generally includes teaching classes, being available to students and

colleagues outside the classroom, serving departmental, college, and university

committees, providing clinical services (where applicable), conducting research,

publishing scholarly works, and otherwise meeting the changing needs of the

university. Those holding Cooperative Extension or clinical appointments have

specified obligations of service to the public.

Such an appointment constitutes a full-time obligation to the university, and, with the

exceptions explicitly permitted by university policies on consulting and other related

professional activities (see the Related Resources section of this policy), full-time

faculty members must not engage in other employment.



Note: Rules on consulting are addressed in the Faculty Handbook (see the Related

Resources section of this policy).

Nonacademic Staff

In the case of staff members, commitments of time and the expectations attached to

such positions are more explicitly defined, and therefore the likelihood of conflicting

external activities is reduced. Nevertheless, the university expects that staff members

also will recognize the possibility that their external activities and commitments may

have adverse effects on the performance of their university obligations.

Part-Time Appointees

Faculty and staff members who hold part-time appointments commonly will have

major obligations and commitments, not only to the university, but also to one or

more outside entities. The potential for conflict may be significant. Accordingly, part-

time employees are expected to exercise special care in reporting and fulfilling their

multiple obligations.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

RINCIPLES

continued

Community, Civic,

and Governmental

Activities

The university encourages participation in community, civic, and governmental

activities. As with other external engagements, employees who consider serving in

elected or appointed positions on local government councils, boards, and

commissions should report and discuss such part-time opportunities with their

supervisors to ensure that there is no conflict with their primary commitment to the

university. See appendix B for guidance on how to determine when recusal is

required.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

Trustees, Overseers,

Officers of the

Corporation, and

Other Senior

Administrators

Conflicts of Interest



Reporting

Any member of the board of trustees, board of overseers, an officer of the

corporation, or other senior administrator must report annually, in writing,

any external interests, or those of a family member or associate, to the

university counsel and secretary of the corporation, in such form as he or she

directs. The university counsel and secretary of the corporation will advise

the Audit Committee of the board of trustees regarding such matters as

necessary.



Managing

The university counsel and secretary of the corporation manages conflicts,

consulting, where appropriate or necessary, with the Committee on Conflicts

of Interest of the board of trustees, which consists of the chair of the board,

the vice-chairs, if any, the chair of the Executive Committee, the chair of the

Audit Committee, and the president of the university. Where appropriate or

necessary, the university counsel and secretary of the corporation and the

Committee on Conflicts may refer the matter to the board of trustees for

management.

Conflicts of Commitment



Reporting

Any member of the board of trustees, an officer of the corporation, or other

senior administrator must report, in writing, any external commitments to

the university counsel and secretary of the corporation, in such form as he or

she directs. The university counsel and secretary of the corporation will

advise the Audit Committee of the board of trustees regarding such matters

as necessary.



Managing

The university counsel and secretary of the corporation manages conflicts,

consulting, where appropriate or necessary, with the Committee on Conflicts

of Interest of the board of trustees, which consists of the chair of the board,

the vice-chairs, if any, the chair of the Executive Committee, and the

president of the university. Where appropriate or necessary, the university

counsel and secretary of the corporation and the Committee on Conflicts may

refer the matter to the board of trustees for management.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

Deans, Directors, and

Academic Unit

Heads

Conflicts of Interest



Reporting

Deans and directors of the colleges, schools, and units defined at Article I,

Section 7 of the university bylaws must file annual statements with the

provost or provost for medical affairs, or designees, reporting any external

interests, or those of a family member or associate, in such form as the

provost or provost for medical affairs may direct.



Managing

The provost or provost for medical affairs, or designees, will manage

conflicts in such cases.

Conflicts of Commitment



Reporting

Deans and directors of the colleges, schools, and units defined at Article I,

Section 7 of the university bylaws must file annual statements with the

provost or provost for medical affairs, or designees, reporting any external

commitments in such form as the provost or provost for medical affairs may

direct.



Managing

The provost or provost for medical affairs, or designees, will manage

conflicts in such cases.

Academic and

Nonacademic Staff

Members Involved in

Research

Conflicts of Interest



Reporting

Members of the faculty or staff who are involved in the design, conduct,

reporting, or direct administration of research must report their potential

conflicts of interest pursuant to University Policy 1.7, Financial Conflict of

Interest Related to Research.



Managing

Conflicts of interest related to members of the faculty or staff who are

involved in the design, conduct, reporting, or direct administration of

research are managed in accordance with University Policy 1.7, Financial

Conflict of Interest Related to Research.

Conflicts of Commitment



Reporting

Members of the faculty or staff who are involved in the design, conduct,

reporting, or direct administration of research must report their potential

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

conflicts of commitment through the process defined in University Policy 1.7,

Financial Conflict of Interest Related to Research. The Office of Research

Integrity and Assurance (ORIA) will forward reports to the college, division,

or other administrative unit in which the individual is employed.



Managing

The appropriate vice president, vice provost, dean, or director, or his or her

designee, will receive reports and manage potential conflicts of commitment.

All Other Academic

Staff

Conflicts of Interest and Commitment



Reporting

Members of the academic staff must report their external financial interests

and commitments through the process defined by ORIA. ORIA will forward

reports to the college, division, or other administrative unit in which the

individual is employed.



Managing

The appropriate vice president, provost, vice provost, dean, or director, or his

or her designee, will receive reports and manage any non-research-related

potential conflicts of interest and commitment.

All Other

Nonacademic Staff

Conflicts of Interest



Reporting

Any other member of the faculty and staff will report information concerning

his or her external interests, or those of a family member or associate, to the

college, division, or other administrative unit in which he or she is employed,

in such form and manner as the vice president, vice provost, dean, or director

(“unit head”), or his or her designee, may prescribe.

Individuals have an obligation to report in a manner that is sufficiently

detailed to permit an accurate and objective evaluation and to cooperate fully

in the review of the pertinent facts and circumstances. Staff members

involved in the following duties must be particularly conscious of possible

conflicts or the appearance of such conflicts: the procurement, exchange, or

sale of goods, services, or other assets; the negotiation or formation of

contracts or other commitments affecting the assets or interests of the

university; and the handling of confidential information and the rendition of

professional advice to the university.



Managing

Conflicts of interest are reviewed at the college, department, or other unit

level. In the event that reported information reveals a conflict or appearance

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

of conflict, the unit head or designee will review the facts and manage the

conflict. Proper management may include disclosure to other members of the

university community of an individual’s role in an external entity.

Conflicts of Commitment



Reporting

Any member of the faculty and staff will report all potential conflicts of

commitment, including consulting agreements, to the college, division, or

other administrative unit in which the individual is employed in such form

and manner as the vice president, vice provost, dean, or director (“unit

head”) or designee may prescribe.



Managing

Conflict of commitment disclosures are reviewed at the college, department,

or other unit level. In the event that reported information reveals a conflict,

the unit head or designee will review the facts and manage the conflict.

Managing

Reporting-Line

Conflicts (Including

Avoiding Nepotism)

In situations where a staff or faculty member is in the direct line of authority over a

family member, or someone with whom they are in a consensual relationship, the

university official to whom the more senior of the two reports will be the “responsible

university official.”



Note: For the purposes of this policy, a department chair reports to the Dean; deans

and vice provosts report to the Provost; provosts and the executive vice president

(EVP) report to the President; vice presidents report to the President, provost or EVP

and the President reports to the Chair of the Board of Trustees. The University

Counsel reports jointly to the President and board of trustees.

The “responsible university official” is required to ensure that consequential

personnel decisions (see “Definitions”) concerning the supervised family member, or

individual in a consensual relationship, are:



made objectively,



in the university’s interests, and



not influenced by personal or family interests of the family members.

Toward that end, the “responsible university official” must:

1. Fully consider potential or current employment (reporting-line) conflicts

brought to his or her attention.

2. Discuss the conflict with the local HR representative and the more senior of

the two reports.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

3. Determine how the conflict and the consequential personnel decisions

concerning the supervised family member, or individual in a consensual

relationship, will be managed, and document the agreed-upon plan

(“conflicts management plan”).

4. Share the conflicts management plan with both family members/individuals

and all intermediate supervisors.

5. Retain the conflicts management plan in HR files.

6. Monitor consequential personnel decisions affecting the supervised family

member , or individual in a consensual relationship.

Appeals

In the event that the faculty or staff member objects to the resolution recommended

by the unit head or designee, he or she may ask for the matter to be referred to an

advisory committee appointed by the provost or provost for medical affairs. The

committee will consider the matter and recommend a resolution to the provost or

provost for medical affairs. The provost or provost for medical affairs may accept,

reject, or modify the committee’s recommendation. If the member disagrees with the

provost's determination, the individual may request a further consideration of the

matter and, in that connection, may examine the recommendations of the advisory

committee, including supporting evidence, and offer other relevant information or

explanations. The university counsel shall serve as advisor to the provost. Following

such reconsideration, the provost shall make a final and binding determination in

writing.

If the determination requires the termination of a faculty member’s appointment, the

procedures described in the Dismissal/Suspension Policy for Faculty Members will

apply.

A staff member may invoke the nonacademic Human Resources Policy 6.11.4, Staff

Complaint and Grievance Procedure (at the Weill Cornell Medical College, Employee

Complaint and Grievance Procedure) (see Related Resources). In the event that a staff

member may be entitled to arbitration of the proposed resolution, the arbitrator may

reject or modify the proposed remedy but shall have no authority to alter the

determination of the university regarding the meaning, interpretation, or

applicability of this policy. Members of collective bargaining units may invoke the

applicable contract grievance procedure.

Sanctions for Non-

Compliance

Any member of the academic staff who does not comply with reporting requirements

will be subject to sanctions outlined in University Policy 1.7, Financial Conflicts of

Interest Related to Research.

Any member of non-academic staff engaged in research who does not comply with

reporting requirements will be subject to sanctions outlined in University Policy 1.7,

Financial Conflicts of Interest Related to Research.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

For all others, sanctions for non-compliance with reporting or conflict of interest

management will be imposed by the respective unit head.

Reporting Suspected

Conflicts of Others

Any member of the Cornell University community may report known or suspected

conflicts of interest or commitment. Reporting must be handled in a confidential

manner. If you suspect that someone else has a conflict, you may report this

information to your supervisor, to the University Audit Office, or through the Cornell

Hotline, at (866) 384-4277 (toll-free) or www.hotline.cornell.edu.

University Conflicts

Committee (UCC)

Purpose

The University Committee on Conflicts (UCC) is established by the president to serve

as a university resource with respect to matters involving the general subject of

conflicts of interest and commitment and the oversight and implementation of this

policy.

Composition

The UCC is co-chaired by the dean of the faculty and the senior vice provost for

research and must include not fewer than five additional members appointed by the

president, including faculty representation from the endowed and contract colleges

in Ithaca. Members serve three-year staggered terms. The university counsel serves as

a non-voting member. To the extent practicable, the UCC should include

representatives from the physical, biological, and social sciences, the humanities,

engineering, medicine, and veterinary medicine.

Duties

A. General Oversight

The UCC is responsible for general oversight over the identification and

management of conflicts of commitment and of conflicts of interest that are

not related to the design, conduct, reporting, or direct administration of

research.

B. Advisory Role

The UCC maintains an ongoing awareness of college procedures, practices,

and standards, with a view toward assuring consistency.

The UCC provides advice and recommendations to the provost on matters

related to conflict of interest and commitment.

The UCC may recommend to the provost changes to this policy.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

ROCEDURES

continued

C. Reporting

The UCC reports biennially to the faculty and to the president on matters

within its jurisdiction.

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

CORNELL CAMPUS UNITS

Conflicts

Management Office

(CMO)

The provost for medical affairs of Weill Cornell Medical College (WCMC) or his/her

designee shall establish a conflicts management office, which shall be responsible for

the overall management of issues related to conflicts of interest and commitment. The

office shall be responsible for the following:



Implementing the WCMC conflicts policy



Serving as a resource to the faculty and staff regarding questions relevant to

issues of conflict of interest or commitment and regulations related to

conflicts of interest



Collecting an annual disclosure of conflict related information from the

faculty and staff



Evaluating information submitted in the annual disclosure as well as other

individual disclosures



Developing and implementing conflicts management plans



Providing staff support for the Conflicts Advisory Panel (see below) and for

any conflicts oversight committees



Developing educational programs for faculty and staff regarding conflicts

related issues

The Conflicts Management Office (CMO) shall establish procedures to fulfill these

responsibilities consistent with this policy.

The CMO shall be under the direction of the dean or his/her designee.

Conflicts Advisory

Panel

The provost for medical affairs shall appoint a Conflicts Advisory Panel (CAP)

consisting of the chairman of the General Faculty Council and between four and ten

members of the faculty of the medical college (at least two of whom shall hold the

rank of professor).

The CAP shall, upon request, (1) provide advice to the dean or his/her designee,

the associate dean and the CMO, in consultation with other staff members to the

panel such as the associate university counsels, with regard to conflicts of interest

and commitment-related matters; (2) advise and make recommendations to the

dean on the acceptability of conflicts management plans submitted to the panel by

the CMO on behalf of members of Cornell regarding potential conflicts of interest

or commitment. In addition to reviewing conflicts management plans submitted

by the CMO, the CAP will also review possible conflicts of interest or commitment

issues as referred to it by the Office of Sponsored Research Administration

(OSRA), Joint Clinical Trials Office (JCTO), Office of BioPharma Alliances and

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

Research Collaborations, Office of the University Counsel, the Center for

Technology Licensing (CTL), the Institutional Review Board (IRB), and the

Institutional Animal Care and Use Committee (IACUC).

Conflict Disclosure

WCMC employees are required to report conflicts annually via the Conflicts Survey

and to update their Conflicts Survey any time they develop a financial relationship

related to their institutional/WCMC responsibilities that may present, or appear to

present, a conflict of interest. Any new relationships must be reported through the

Conflicts Survey within 30 days of acquiring them. Additional regulations apply for

investigators applying for or using PHS funding. See policy 7.171.7 for conflicts

reporting policies related to research.

Annual Conflicts Survey Submission Requirements:

New Appointments: Upon the appointment of a new faculty member, academic/non-

academic staff member, (or other employee), the new appointee must complete

Conflicts Survey within forty-five (45) days of his or her WCMC start date. See policy

1.7 for requirements for medical students and trainees involved in research.

The unit making the appointment is responsible for ensuring that these WCMC

representatives are identified and complete their conflicts survey within the required

timeframe.

Travel Disclosure

Introduction

Various regulatory and oversight groups require institutions to monitor external

funding of travel for their employees involved in research and clinical care. These

include rules for disclosing Sponsored Travel for individuals applying for or funded

by Public Health Services (PHS), which includes the National Institutes of Health

(NIH) and other non-profit agencies that chose to invoke PHS COI policy. In

addition, travel undertaken by WCMC employees but paid for by industry are now

being reported by industry to the Medicare Open Payments Database (Sunshine Act).

Such information is also relevant to the WCMC conflicts of interest management

disclosure process.

All employees who travel in conjunction with their institutional and professional

responsibilities should familiarize themselves with this travel disclosure policy, and if

required, report externally-funded travel reimbursements accordingly via the Weill

Research Gateway (WRG)

Policy

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

All Sponsored Travel provided by "for-profit" entities must be disclosed within 30

days of completing travel.

Sponsored Travel and other compensation greater than $5,000 per year in aggregate

from a single non-profit entity need to be reported. This means that you only have to

report Sponsored Travel by a single non-profit entity if :

• The trip was more than $5,000,

• Multiple trips for that entity in aggregate exceed $5,000,

• You receive more than $5,000 for services from that entity, or

• A combination of trips and services in aggregate from a single entity exceeds

$5,000.

You do not have to report Sponsored Travel for WCMC or Cornell University, nor

Sponsored Travel paid by:

• a federal, state, or local government agency,

• a U.S. non-profit institution of higher education as defined at 20 U.S.C.

1001(a),

• a U.S. academic teaching hospital, U.S. medical center, or

• a research institute that is affiliated with an institution of higher education

There are additional regulations for individuals applying for or funded by Public

Health Services (PHS), which includes the National Institutes of Health (NIH) and

other non-profit agencies that choose to invoke PHS COI policy. Investigators and

others involved in research sponsored by these entities must disclose their

reimbursed or sponsored travel related to their institutional responsibilities over the

previous twelve-month period no later than at the time of application for PHS-funded

research and after that, within 30 days of completing reimbursed travel. This includes

reimbursed or sponsored travel received by the Investigator’s spouse and dependent

children that is also related to the individual’s institutional responsibilities.

Investigators applying for or funded by PHS sponsors should familiarize themselves

with these regulations, which can be found at http://www.ecfr.gov/cgi-bin/text-

idx?rgn=div5&node=45:1.0.1.1.51. Answers to frequently asked questions about these

regulations can be found at http://grants.nih.gov/grants/policy/coi/coi_faqs.htm#3451.

Travel reimbursements should be reported via the Weill Research Gateway (WRG)

either by filing a separate travel disclosure and/or checking the travel reimbursement

box when disclosing a financial interest for a given entity in your Conflicts Survey.

(See WRG for instructions on how to complete a travel disclosure.)

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

To the extent possible, listing all potential travel prospectively on your travel

disclosure will reduce or eliminate the need to file updates throughout the year.

If in doubt, please disclose the travel and the Conflicts Management Office staff will

determine what needs to be reported. If you need further explanation or have

questions about a travel disclosure or entity, please contact the Conflicts Management

Office at (646) 962-8200 or conflicts@med.cornell.edu.

Definitions

Sponsored travel means (a) travel expenses paid to a WCMC employee or travel paid

on a WCMC employee’s behalf, by a single entity in any twelve-month period and/or

(b) travel reimbursed to or paid on behalf of a WCMC employee’s spouse and

dependent children by a single entity in any 12-month period.

For-Profit Entities generally refers to pharmaceutical and device manufacturers,

technology and imaging companies and other entities whether publicly or privately

held, including start-ups or other entities in which WCMC employees may have

interest.

Not-for Profit Entities, for the purposes of travel reporting, fall into one of two

categories:

• Travel expenses not required to be reported -

o a federal, state, or local government agency,

o a U.S. non-profit institution of higher education as defined at 20

U.S.C. 1001(a),

o a U.S. academic teaching hospital, U.S. medical center, or

o a research institute that is affiliated with an institution of higher

education

• Travel Expenses subject to reporting based on amount >$5,000 when

combined with other compensation -

o Non-Profit Health Foundations (e.g., American Heart Association,

Koman Foundation, North American Menopause Society )

o Non-Profit Professional Organizations (e.g., American College of

Radiology, American Society of Clinical Oncology, College of

Internal Medicine)

o Non-Profit Research Organizations NOT affiliated with an institution

of higher education (e.g., Gordon Conferences)

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

Sanctions and

Disciplinary Actions

In the event that the faculty, staff member, or student does not comply with the

disclosure of financial interests or outside commitments, sanctions and disciplinary

actions may include, but are not limited to, the following:

1. The inclusion in the faculty or staff member’s file of a letter from the provost

for medical affairs indicating that the individual’s good standing as a member

of the faculty or staff has been called into question, i.e., censure

2. Ineligibility of the faculty or staff member to submit sponsored project

applications, enter into technology transfer agreements, to teach or organize

Continuing Medical Education programs, to obtain Institutional Review

Board (IRB) or Institutional Animal Care and Use Committee (IACUC)

approval, or to supervise graduate students

3. Withdrawal of the individual’s annual salary increment

4. Non-renewal of appointment or termination of employment

5. Dismissal from the university

Department Chairs/Unit Heads and the Department Administrators (DA’s) will be

notified if faculty and non-faculty within their respective department/unit does not

comply with the completion and/or submission of the conflicts survey within forty-

five (45) days of hire OR when annual re-certification of the conflicts survey are not

completed by the reporting deadline. The CAP will monitor instances of non-

compliance and may recommend to the Department Chair/Unit Head the

enforcement of appropriate Sanctions and Disciplinary Actions.

Right to Appeal

Faculty and staff members have the right to appeal all sanctions proposed by the

provost for medical affairs.

If the member disagrees with the provost’s determination, the member may request

further consideration of the matter and may then examine the recommendations of

the CAP, including supporting evidence, and offer other relevant information or

explanations.

The university counsel shall serve as advisor to the provost for medical affairs.

Following such consideration, the provost shall make a final and binding

determination in writing.

Industry

Relationships

Equity and Stock Holdings in External Entities based on Faculty Technologies

Equity and stock holdings are defined as monetary investments, held by a WCMC

representative or his/her family tied to the financial standing of an external entity.

This policy refers specifically to entities that have licensed technology developed at

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

WCMC through agreement with the Cornell Technology Licensing (CTL). Refer to

the ‘Equity and Stock Holdings in External Entities Not Based on Faculty

Technologies’ for specific information regarding these types of relationships. WCMC

representatives holding equity/stock with an entity that also supports his/her

research are strongly encouraged to speak with the Conflicts Advisory Panel (CAP)

prior to entering into any research agreements with such an entity.

Agreements made between the WCMC representative conducting clinical research

and the entity related to his/her research, specifically those in which the WCMC

representative or his/her family is expected to receive $5,000 (or the active de minimis

threshold required for disclosure by the National Institutes of Health included in 42

CFR Part 50 Subpart F) or more annually, may be subject to increased scrutiny from

the Office of Research Integrity and/or Conflicts Advisory Panel. In such cases,

additional and/or supplemental information may be required by the Conflicts

Advisory Panel in order to determine the appropriateness of such relationships and

whether or not the arrangement should be allowed, monitored or modified. Final

determination on the permissiveness of consulting arrangements in these

circumstances will be made at the discretion of the Conflicts Advisory Panel in

consultation with the appropriate WCMC representative(s). While the holding of

equity/stock options by WCMC representatives in such cases may be permissible,

these types of relationships may be subject to increased scrutiny by the CAP and will

require the implementation of a comprehensive conflicts management plan.

Research involving human participants is critical in developing knowledge and

discoveries that will benefit society. Protecting the rights and welfare of human

research participants is of the utmost importance and a requirement of all research

personnel and the university. Of particular concern, therefore, are external

commitments and financial interests that compromise or appear to compromise the

rights and well-being of human research participants. The university scrutinizes the

roles in such research of research personnel who have external commitments and

financial interests with a sponsor or with an external entity that is related to, or can be

affected by, the research. The university has instituted a rebuttable presumption that

research personnel who are involved in the design, participant selection, informed

consent process, or the clinical management of a trial cannot have a financial interest

in an entity whose interest could be affected by the research. In other words, the

default position is that participation in human participant research by conflicted

research personnel is not allowed. However, there may be compelling circumstances

in which conflicted research personnel would be permitted to participate in the

research. In these cases, the management strategies for the involvement of conflicted

researchers must be carefully adjusted to the level of anticipated risk. All financial

interests and external relationships related to human-participant research that are not

eliminated must be disclosed to all participants in the related research. The

Cornell Policy Library

Volume: 4, Governance/Legal

Responsible Executive:

Provosts/University Counsel

Responsible Office:

Provosts/University Counsel

Originally Issued: May 31, 1986

Last Updated: January 31,

2020

POLICY 4.14

Conflicts of Interest and Commitment (Excluding Financial Conflict of

Interest Related to Research)

DDITIONAL

ROCEDURES

PECIFIC

EILL

ORNELL

CAMPUS UNITS, continued

management plan must be implemented before research personnel can participate in

the design or conduct of the research, enrollment of participants, or analysis of the

results.

Equity and Stock Holdings in External Entities Not Based on Faculty Technology

Equity and stock holdings are defined as monetary investments, held by a WCMC

representative or his/her family tied to the financial standing of an external entity.

This policy refers specifically to entities that have not licensed technology developed

at WCMC through agreement with the Cornell Technology Licensing (CTL). Please

refer to the ‘Equity and Stock Holdings in External Entities Based on Faculty

Technologies’ for specific information regarding these types of relationships. This

policy does not refer to diversified mutual funds not under the control of the WCMC

representative. WCMC representatives holding equity/stock with an entity that also

supports his/her research are strongly encouraged to speak with the Conflicts

Advisory Panel (CAP) prior to entering into any research agreements with such an

entity.

Agreements made between the WCMC representative conducting research and the

entity related to his/her research, specifically those in which the WCMC