Determining if an SFI is Related

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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:

Lehigh University Conflict of Interest policy and Internal Audit contact information is available here:

Example Circumstances in which a Significant Financial Interest is Related to Sponsored Programs or University Research

An SFI in an External Entity would be reasonably considered Related to an Investigator's University Research or Sponsored Programs in circumstances such as the following:

  • The External Entity is a collaborator on or provider of materials, products, data or trainee support for the research or is a licensee with improvement rights to technology likely to arise out of the research. 
  • The Investigator or the External Entity has financial interests that could reasonably be considered to have a potential influence on the design, conduct or reporting of the research.
  • The External Entity has a reasonable possibility of being financially affected by the research.
  • The External Entity sponsors research at Lehigh University in which the Investigator is directly involved.
  • The External Entity makes gifts to Lehigh University that benefit Investigator's research/scholarship (including equipment gifts or loans).
  • The External Entity sponsors or makes a product that is under study in research in which Investigator is involved.
  • The External Entity sponsors or makes a product that is under study in human subjects in which Investigator is directly or indirectly involved. 
  • The External Entity licenses Lehigh University intellectual property in which Investigator has a financial interest.
  • The External Entity owns intellectual property, materials, or data that may be used in research at Lehigh University. 
  • The External Entity has a Materials Transfer Agreement, Human Tissue Agreement (MTA/HTA), or Data Transfer and Use Agreement (DTUA) to provide materials or data used in Investigator's research or for materials provided by Investigator to the company/organization.
  • The External Entity is the sole-source provider of materials or services or of procurements required for the Investigator to carry out research. 
  • The External Entity provides financial support for the faculty member's trainees (including graduate students and postdoctoral fellows)