East Carolina University Faculty Manual

APPENDIX I.

ECU POLICY ON CONFLICTS OF INTEREST AND COMMITMENT

VI. Review and Approval of Activities and Plans for Eliminating or Managing Conflicts.

The unit administrator (chair, dean, or the employee's supervisor in the case of a senior administrator) has the initial responsibility to review and approve or disapprove the disclosure forms filed with him or her by the EPA employees within that unit. The review shall follow the provisions of this Policy. The Unit administrator should be familiar with the definition of ‘Significant Financial Interest’ (See Section IX) to differentiate between Category II and Category III activities and relationships. Category III activities are presumptively considered to be non-allowable.

The unit administrator may refer any question regarding an annual disclosure form to the next higher administrative level for review and decision and must refer to the next higher level for review and approval all annual disclosures (and updates/revisions) which require additional forms (as described in the annual disclosure form) for EPA employees involvement in possible Category II and III activities as described above.

If a potential conflict is determined to exist, written plans for eliminating or managing the conflict will be developed in consultations between the employee and his/her supervisors and presented to the Vice Chancellor of the appropriate division for concurrence. It will then be presented to the ECU Research Ethics Oversight Committee (see below) for final approval. An adverse decision of the Committee to a proposed management plan may be appealed to the Chancellor. The supervisor of the EPA employee will be responsible for assuring the implementation and/or monitoring of the conflict management plan.

Documentation of all decisions on activities and associated conflict management plans will be maintained in the employee's personnel folder.

In order to fulfill the certification requirements of grant and contract funding agencies (e.g., the NIH and NSF), each unit administrator shall also provide annually to the Vice Chancellor for Research and Graduate Studies a list of all faculty members and EPA staff in the administrator's unit who have submitted approved current annual disclosure forms and, where needed, an indication when such approval required development of an acceptable conflict management plan. This list may be amended as needed during the year. The

Vice Chancellor for Research or his designee will use this information to certify to potential funding agencies that this Institution has a conflict of interest policy consistent with NIH and NSF guidelines and that to the best of our knowledge all provisions of the policy have been followed with respect to proposals submitted to the agencies by ECU faculty and staff.

If after initial review by the department head, dean, and vice chancellor, questions remain regarding ethical issues or if disagreement exists between the EPA employee and the administration regarding the permissibility of activities, the situation may be referred to a faculty/administrative advisory committee for review of conflicts of interest and commitment. This committee, the Research Ethics Oversight Committee, will be chaired by the Vice Chancellor for Research & Graduate Studies and will have representatives from the faculty senate as members. When the committee reviews conflict management plans, a representative of university attorney's office shall be present. In addition, when a management plan involves graduate students, a representative from the graduate council will also be present. Other appropriate individuals will be appointed members to the committee by the Vice Chancellor for Research & Graduate Studies. Decisions by this committee will be presented to the Chancellor for his or her concurrence and, if approved, will become the University's final position subject only to appeal in accordance with Section 501C(4) of The Code of the University of North Carolina.

If the activity at issue involves external support (grant, contract or cooperative agreement), the vice chancellor for research shall inform the sponsor whenever the University determines that it is unable to develop a satisfactory conflict management plan for an actual or potential conflict of interest.

Whenever human subjects are involved in an activity presented to the Research Ethics Oversight Committee (including approvals of conflict management plans), the University & Medical Center Institutional Review Board (UMCIRB) will be confidentially notified of the issue and the Committee’s actions.