Determining if an SFI is Related

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Relatedness Standard as it Pertains to the Disclosure Requirements in the fCOI Related to Research and Sponsored Programs Policy

Project Personnel are required to disclose a Significant Financial Interest (SFI) in an External Entity when the SFI is Related to a Sponsored Program or University Research

Project Personnel should make a reasonable, good-faith determination as to whether the Sponsored Program or University Research could affect the value of a financial interest, or have a financial impact on the External Entity in which they hold an SFI. For example, Project Personnel are not required to disclose a Family member’s salary with a company that’s business focus is not related to the Project Personnel’s Sponsored Program or University Research.

Keep in mind that the relevant fCOI in Research and Sponsored Programs policy pertains only to Lehigh University Sponsored Programs and University Research.

Sponsored Programs are:
• Programs funded by a sponsor through a grant, contract, or agreement with the university, including, but not limited to research, education, testing, outreach, etc., and;
• Programs funded through Lehigh University’s internal grant programs administered by the office of the Vice President and Associate Provost for Research and Graduate Studies (VPR)

University Research is:
• Any research activity supported by university funds, regardless of source.

Internal Audit administers the separate Lehigh University Conflict of Interest policy, which pertains more broadly to all Lehigh University staff, faculty, trustees, and officers external financial interests that may present conflicts of interests related to non-research university activities. If Project Personnel believe they may have a financial interest that does not fall within the scope of the Financial Conflicts of Interest Related to Research and Sponsored Programs policy, but may instead fall within the broader scope of the Lehigh University Conflict of Interest policy, the individual should contact Internal Audit directly.

Financial Conflicts of Interest Related to Research and Sponsored Programs policy is available here: https://research.cc.lehigh.edu/conflicts-interest-sponsored-programs

Lehigh University Conflict of Interest policy and Internal Audit contact information is available here: https://www1.lehigh.edu/internalaudit