Research Compliance

A conflict of interest occurs when a University employee uses or could use their position for personal benefit—or for the benefit of family members or business associates, rather than acting in the best interest of the University.

• Employees must act in a way that maintains public trust and integrity in the University. 
• Ohio ethics laws prohibit using a public position for personal gain or for related individuals or business partners. 
• The concern includes both actual and potential misuse of influence or authority, especially in decisions involving employment, resources, or benefits.

See the Conflict of Interest and Nepotism Policy (3364-25-18) for more details.

Examples of Conflicts of Interest

• Diverting research opportunities from the university to a consulting entity or business in which the faculty/researcher has a financial interest.
• Research conducted whereby any of the involved investigators (or a related person: spouse/domestic partner, dependent children/step-children and any other persons with whom you are financially interdependent) has employment or consulting arrangements and significant financial interests in the sponsor, or with subcontractors, vendors, or collaborators.
• Use of university resources to conduct research or programs that are sponsored by an entity in which the faculty member/researcher or related person has a significant financial interest or could financially benefit.
• Serving as a consultant for an external for-profit entity which sponsors the faculty member’s/researcher’s research/program or provides gift funds for the researcher or his/her department.
• Hiring university students in consulting activities or a company in which the faculty member/researcher has financial interests. If the student’s thesis/dissertation research is supervised by the faculty member, the conflict of interest situation may not be manageable.
• Equity (ownership) interest of the faculty member (or a related person) in a sponsor.
• Failure of the faculty member/researcher to fulfill university responsibilities (e.g., holding classes, advising students, conducting research, serving on departmental or university committees, supervising students in research lab), due to involvement in external activities.
• While acting in the context of his/her university duties, making professional referrals to or purchasing materials or services from a business in which an academic staff member or related person has a financial interest.
• Gifts to the university, of cash or property, which will be under the control, or will directly support the teaching or research activities of a faculty member from an entity in which that faculty member (or related person) has an employment or consulting arrangement and/or significant financial interests.
• Serving on the board of directors or major advisory committee of an external for-profit entity which sponsors the faculty member’s/researcher’s research/pro

The University of Toledo requires all faculty, staff and student researchers to complete COI training as required by their program sponsors. 

[UToledo policy does not talk about conflict of commitment. Do we need to add this to the policy?]

A conflict of commitment occurs when an employee’s outside activities or external affiliations interfere with, or have the potential to interfere with, the fulfillment of their University responsibilities due to competing demands on time or effort. Conflicts of commitment may also arise when University resources are used for non‑University purposes without appropriate authorization or when outside activities detract from an employee’s ability to meet their institutional obligations.

Examples of Conflicts of Interest and Commitment

• Use of University property or resources without authorization in connection with outside activities
• Engagement in outside activities that interfere with or diminish the employee’s ability to fulfill assigned University responsibilities

A financial conflict of interest occurs when an individual’s personal financial interests have the potential to compromise, or appear to compromise, the objectivity and integrity of their professional responsibilities, including the design, conduct, or reporting of research or other sponsored activities.

Investigators must disclose their external financial interests that could create, or appear to create, a conflict with their University responsibilities—particularly those related to the design, conduct, or reporting of sponsored activities. 

See the Financial Conflict of Interest Policy (3364-70-01) for more details

Financial interests must be disclosed to protect the integrity and objectivity of research and other sponsored activities, ensuring that decisions about the design, conduct, and reporting of work are not biased—or perceived to be biased—by personal financial gain. 

Disclosure also allows the University to identify, review, and manage potential conflicts, helping comply with federal regulations and maintain transparency, accountability, and public trust in research and institutional activities.

Researchers—including faculty, staff, students, and collaborators—who are involved in the design, conduct, or reporting of sponsored research or other sponsored activities are required to disclose their financial interests.

Here are step-by-step instructions to complete or download the financial conflict of interest disclosure requirements in InfoEd.

Financial Conflict of Interest (FCOI) disclosures must be made:

• At least annually, and
• Whenever new or changed financial interests arise that could create a potential conflict.

Yes. Disclosures are to be completed annually (each calendar year) and must be updated within 30 days of obtaining new financial or other personal interests.

Yes. Disclosures are to be completed annually (each calendar year).

No. As long as the information in your disclosure is correct and updated.

The following research activities could be delayed or suspended if a current disclosure is not on file:

• any research project (funded or unfunded);
• expenditure of funds from grant or other sponsored program awards;
• submission of grant proposals and contracts;
• approval for the use of human subjects (IRB) or animals in research (IACUC);

Other disciplinary action will occur as required by  UToledo policy, and other applicable agencies, and the granting or sponsoring agency will be notified, if applicable.

Contact coi.disclosure@utoledo.edu.