Conflict of Interest and Conflict of Commitment

Stanford University is an institution of public trust. Stanford personnel (Faculty, Staff, and Postdoctoral scholars) must conduct their affairs in ways that will not compromise the integrity of the university or that trust."

Stanford Research Policy Handbook 4.1

Who We Are

The Conflict of Interest and Commitment team within VPDoR helps the Stanford research community navigate policies related to potential conflict risks, understand the impact of competing interests, and collaborate with stakeholders to ensure proper disclosure and management.

Conflicts of interest are common—and often unavoidable—in a modern research university. Stanford’s policies aim to mitigate the risks associated with these conflicts to protect academic values, research integrity, and the university's mission. Even the perception of a conflict can compromise these principles.

All Personnel are expected to conduct their professional and academic activities in ways that uphold the university’s integrity and public trust. However, they may at times encounter potential conflicts of interest, conflicts of commitment, or both. Such situations do not inherently indicate wrongdoing or inappropriate behavior but are evaluated to determine how they should be managed, whether they can be reduced, or if they need to be eliminated.

Conflict of Interest

A conflict of interest occurs when there is a divergence between the private interests of faculty and their professional obligations to the university such that an independent observer might reasonably question whether the actions or decisions are determined by considerations of personal financial gain.

Conflict of Commitment

Conflict of commitment usually involves issues around time allocation. Stanford faculty owe their primary professional allegiance to the university, and their primary commitment of time and intellectual energies is expected to be devoted to the education, research, and scholarship programs of the institution.

Stanford’s Policy on Conflicts of Commitment and Interest describes the potential conflict risks regarding consulting and other professional activities. It also details the requirements for how faculty, staff, and others must address these risks through disclosure, and provides information about how Stanford reviews and assesses personal financial interests related to the university responsibilities of faculty. More information is available in the Research Policy Handbook. 

Understanding Conflicts

Conflict of Interest

Conflicts of interest often arise at the intersection of two fundamental missions: to push the boundaries of knowledge and to transfer that knowledge to the private sector for the benefit of the public. There may be significant personal financial incentives related to outside consulting, patenting and licensing an invention, or being involved with a startup company. Considerations of personal financial gain, however, must not influence the decisions or actions of individuals in carrying out their university responsibilities.

Significant Financial Interests are defined as:

Payments for services over $10,000/year or ownership of stock/stock options in a publicly traded company valued at over $10,000 or 0.5% of the total value of the company

Ownership or promise of stock or stock options of any amount in a privately held or startup company

Conflict of Commitment

Conflict of commitment usually involves issues around time allocation. Stanford faculty Personnel owe their primary professional allegiance to the university, and their primary commitment of time and intellectual energies is expected to be devoted to the education, research, and scholarship programs of the institution.

Whenever Personnel’s outside professional activities exceed the permitted limits (normally thirteen days per quarter), or whenever full-time Personnel’s primary professional loyalty is not to Stanford, a conflict of commitment exists. Due to conflict of commitment concerns, Stanford prohibits direction of a program of research or scholarship at another institution that could be conducted appropriately at Stanford (i.e., outside PI-ship).

Types of Conflicts

Conflicts in Research

Financial interests can influence or appear to influence the choice of research direction, study design and conduct, objectivity of data, or interpretation of research results. In human research, opportunities to profit may influence a researcher's judgments about which subjects to enroll, clinical care provided, and the proper use of subjects' confidential health information.

Conflicts in Teaching and Educational Activities

Education and guidance given to students by faculty should be governed by what is in the academic interest of the student. Personal financial interests should not influence the content of any educational activity or presentation, and any related financial interests should be disclosed.

Conflicts in Administrative Responsibilities

A financial interest could create a conflict if:

The faculty member is directly involved or in a position to influence decisions to purchase goods/services from an entity

Another faculty member who reports to this faculty member is engaged in human subjects research related to the interests of an entity

Conflicts in Clinical Care

The School of Medicine has a specific policy on Conflicts of Interest in Clinical Care. Stanford physicians must fully disclose financial relationships with companies that produce medical devices, implants, pharmaceuticals, biologics, diagnostics, or other medical care-related products that may be used in patient care.

Disclosure Requirements

Stanford provides two web-based applications to facilitate the disclosure and management of potential conflicts of commitment and interest: the Outside Professional Activities Certification System (OPACS) and the PHS Travel Report module.

Prior-Approval of Outside Professional Involvement

Stanford Personnel receive required prior approval of outside professional activities through OPACS. Activities requiring prior approval include the following, when similar to Stanford responsibilities:

Employment and appointments outside of Stanford
Formation or acquisition of a new entity
Outside relationship with an entity licensing Stanford intellectual property on which they are an inventor
Services on boards outside of Stanford, unless it constitutes a Professional Service
Consulting activities

Annual Disclosure Requirements

Annually, all Stanford Personnel are required to certify their understanding of and compliance with Stanford policy through OPACS.

Transactional Disclosures

Whenever potential conflicts arise, individuals must submit a transactional disclosure. Transactional conflicts of interest can be triggered by any of the following:

Technology licensing arrangements or other industrial contracts including Material Transfer Agreements
Filing of a protocol for the protection of humans, stem cells, or laboratory animals in research
Submission of a proposal or contract to a research sponsor
Acceptance of gifts
Certain procurement activities

Personal financial interests may be related if a company/organization:

Sponsors research at Stanford in which the investigator is directly involved
Makes a product under study in the investigator's research
Has financial interests that could influence the design, conduct, or reporting of research
Has a reasonable possibility of being financially affected by the investigator's research
Makes gifts to Stanford that benefit the investigator's researchicenses
Stanford intellectual property in which the investigator has a financial interest
Has Material Transfer Agreements, Human Tissue Agreements, or other Research Related Agreements with the investigator
Has interests related to the investigator's general scientific or scholarly expertise

PHS Travel Reporting

Researchers receiving Public Health Services funding must disclose reimbursed or sponsored travel related to institutional responsibilities at Stanford regardless of the relationship of the travel to PHS funding when the amount from a particular entity exceeds $5,000 during the preceding 12 months.

Managing Conflicts

Assessing Conflicts

Financial interests above thresholds that are disclosed and deemed related to research responsibilities will be reviewed to determine if the financial interest could have a direct and significant effect on research performance.

Elimination, Mitigation, or Management Strategies

If a significant financial interest could directly and significantly affect research, the conflict will need to be eliminated or managed.

Common strategies include:

Public disclosure of significant financial interests
Training on conflicts of interest and commitment for all involved students and personnel
Independent monitoring and oversight of the activity
Modification of research activity to remove the conflicted faculty member from participation
Divestiture of significant financial interests
Other mitigating strategies

Conflict of Interest Officers by School

Requirements and policies often differ depending on the type of research engagement. COI officers are available as resources throughout the Stanford campus. Find the COI officer for your school or department in this list.