E. Financial Conflicts of Interest in Research

(Note: OLPM sections on this page may be cited following the format of, for example, "UNH.VIII.E.1.1". These policies may be amended at any time, do not constitute an employment contract, and are provided here only for ease of reference and without any warranty of accuracy. See OLPM Main Menu for details.)

Interim policy effective August 17, 2026¹

Summary:

Externally sponsored research is vital to UNH, and its overlap with private interests can create financial conflicts of interest. This policy, and related training and procedures, are intended to protect research integrity by identifying and managing those financial interests that could influence research.

Anyone at UNH who is responsible for the design, conduct or reporting of externally funded research is subject to this policy, and must disclose relevant financial interests. Disclosures are reviewed by institutional officials, and, when necessary, management plans are created and compliance is monitored through ongoing oversight and periodic review.

1.   Statement of Need and Purpose

1.1   Externally sponsored Research is a vital part of the University of New Hampshire (UNH) mission. As this activity grows in sophistication and complexity, it intersects increasingly with industrial explorations and entrepreneurial ventures, creating for Investigators the potential for conflicting interests.

1.2   A Financial Conflict of Interest in Research exists when it can be reasonably determined that an Investigator’s personal financial concerns could directly and significantly influence the design, conduct, or reporting of sponsored Research activities. UNH Investigators have an obligation to maintain the objectivity of their Research to avoid any actual, perceived, or potential Financial Conflict of Interest in Research.

1.3   UNH has developed this policy as part of a larger program to protect the integrity and objectivity of sponsored Research and to comply with federal financial conflicts of interest regulations. It is the intent and policy of UNH, as an institution of higher education in receipt of federal Research support, to comply with present and future regulations. To that end, this policy is subject to further refinement as other rules are published.

1.4   Specifically, the intent of this policy is to identify and eliminate or manage threats to objectivity in externally funded Research at UNH due to financial conflicts of interest, including those that affect the rights and welfare of human Research participants. The main components are disclosure of Investigators’ Financial Interests that might be affected by the Research, and application of methods to minimize or eliminate the risks associated with such connections. It is not meant to discourage, but rather to safeguard, the pursuit and dissemination of knowledge.

2.   Definitions

2.1   Disclosure Statement: An Investigator’s disclosure of Significant Financial Interests to UNH.

2.2   Disclosure Review Committee (DRC): A UNH committee charged with protecting the integrity of UNH's academic and Research enterprise from the detrimental effects of competing obligations.

2.3   Financial Conflict of Interest in Research (FCOIR): A Significant Financial Interest that could directly and significantly affect the objectivity of externally funded Research.

2.4   Financial Interest: Anything of monetary value, whether or not the value is readily ascertainable.

2.5   Institutional Official (IO): UNH’s Vice President for Research and Innovation or their designee.

2.6   Investigator: The project director or Principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of Research funded by external sources, or proposed for such funding, which may include, for example, collaborators or consultants.

2.7   Manage: Taking action to address an FCOIR, which can include reducing or eliminating the FCOIR, to ensure, to the extent possible, that the Research will be free from bias.

2.8   Principal Investigator (PI): The principal investigator, program director, or other term used by the sponsor to denote the individual primarily responsible for the conduct and oversight of an externally funded Research project.

2.9   Research: A systematic investigation, study or experiment designed to develop or contribute to generalizable knowledge. The term encompasses basic and applied research (e.g., a published article, book, or book chapter) and product development (e.g., a diagnostic test or drug).

2.10   Significant Financial Interest: In the absence of a definition by the external sponsor, a current Financial Interest consisting of one or more of the following interests of the Investigator (and/or those of the Investigator’s spouse or domestic partner, and/or dependent children) that could reasonably appear to be affected by the funded Research activities or Research activities proposed for funding.

2.10.1   Specifically, Significant Financial Interests might include, but are not limited to, any of the following:

2.10.1.1   Anything of significant monetary value, including salary or other payments for services such as consulting fees or honoraria;

2.10.1.2   Direct ownership, or equity interests such as stock or stock options, of a business entity (company, corporation, or other enterprise);

2.10.1.3   Venture or other capital financing;

2.10.1.4   Intellectual property rights and interests owned by the Investigator such as patents, copyrights, and royalties from such rights and interests. As further described in 2.10.2.2, this does not include intellectual property rights and interests assigned to UNH nor royalty income received from UNH per the UNH Intellectual Property policy (UNH VIII.D).

2.10.2   Significant Financial Interests do not include:

2.10.2.1   An equity interest that, when aggregated for the Investigator and the Investigator’s spouse/domestic partner and dependent children, meets both of the following tests:

2.10.2.1.1   Does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and

2.10.2.1.2   Does not represent more than a five percent ownership interest in any single entity.

2.10.2.2   Salary, royalties, or other remuneration from UNH;

2.10.2.3   Salary, royalties, or other payments that, when aggregated for the Investigator and the Investigator’s spouse/domestic partner and dependent children, are not expected to exceed $10,000 during the prior 12-month period;

2.10.2.4   Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;

2.10.2.5  Income from service on advisory committees or review panels for public or non-profit entities.

3.   Applicability

3.1   This policy applies to any UNH Investigator participating in a Research activity funded or proposed for funding by an external sponsor. 

3.2   This policy is intended to reflect the minimum requirements for who is covered by this policy, the definition of Significant Financial Interest, disclosure of a Significant Financial Interest, determination of when an FCOIR exists, Management of any such FCOIR, reporting of a new Financial Interest, and training. External sponsors may have additional or different requirements with which UNH and UNH Investigators must comply in applying for, accepting and/or participating in an award.² 

4.   Statement of the Policy

4.1   PIs are responsible for ensuring that all members of the team on an externally funded Research project (or a Research project proposed for external funding) complete required training regarding FCOIR and follow the sponsor terms requiring disclosure and any subsequent Management of FCOIR. In the absence of such requirements, or if such requirements do not meet the minimum requirements set forth in this policy, PIs are responsible for ensuring that all members of the Research team follow the training, Disclosure Statement and Management requirements of this policy.

4.1.1   Individuals who begin work on an established project through reallocation of effort, hiring, transfer, promotion, etc., and thereby take on a responsible position in a project, must also disclose any such Significant Financial Interests and complete training within the timeframe(s) specified by the sponsor or, in their absence, by this policy.

4.2   Collaborators, subcontractors, subrecipients, and visiting scientists who qualify as Investigators or are otherwise covered by the applicable sponsor’s policies must either comply with this policy or provide a certification to the UNH IO and to UNH Sponsored Programs that their institutions comply with pertinent sponsor policies and that they in turn comply with their own institutional policies.

5.   Training

5.1   Investigators must complete training regarding conflicts of interest prior to engaging in externally funded Research and at least every four (4) years.

5.2   In addition, an Investigator must re-complete training within thirty (30) days if UNH finds that the Investigator is not in compliance with this policy or the Investigator’s Management plan.

6.   Disclosure Process

6.1   Each Investigator on Research funded or proposed for funding at UNH by external sources must disclose their Significant Financial Interests as required by the sponsor or at least annually and update such Disclosure Statement:

6.1.1   Within thirty (30) days after any new reportable Significant Financial Interest is obtained; and

6.1.2   Within thirty (30) days prior to engaging in Research activities on an externally funded Research award.

6.2   Investigators shall submit Disclosure Statements required by this policy via the means designated by the UNH IO and attach any requested supporting documentation. If the Disclosure Statement indicates involvement of human subjects in the Research, the IO or their designee will notify the chairperson of the UNH Institutional Review Board for the Protection of Human Subjects in Research (IRB) so the situation may be considered, and, if appropriate, addressed by the IRB.

6.3   An Investigator may choose to disclose any other Financial Interest or related interest that might present an actual, potential, or perceived FCOIR. Disclosure can be a key factor in protecting an Investigator’s reputation and career from potentially harmful allegations of inappropriate conduct.

6.4   All Disclosure Statements and related documents are considered sensitive information. As such, they will be treated as confidential and will not be disclosed outside the Vice President for Research and Innovation (VPRI) office and its staff, the Investigator’s Department Chair, Dean/Director, or supervisor, the DRC, and the USNH General Counsel’s Office without the Investigator’s consent except: (a) as required by sponsor award terms; (b) in response to a request from a sponsor; (c) pursuant to a judicial order or lawfully issued subpoena; or (d) as permitted or otherwise necessary under this policy. UNH will make reasonable efforts to notify the Investigator of any judicial order or lawfully issued subpoena in advance of disclosure of this information unless the order is from a federal grand jury or is for law enforcement purposes and its terms prohibit UNH from disclosing its existence or contents.

7.   Review of Disclosure Statements

7.1   The UNH Research Integrity Services Office (RIS) will review all Disclosure Statements.

7.2   RIS will be responsible for determining whether the Significant Financial Interests of the Investigator could reasonably be expected to affect the design, conduct, or reporting of the Research activities funded or proposed for funding, and, if so related, whether the Significant Financial Interest represents an FCOIR. As part of the review and determination process, RIS may (a) involve the Investigator; (b) request additional clarifying information from the Investigator and/or the Investigator’s Department Chair, Dean/Director, or supervisor; (c) consult the DRC; or (d) consult with individuals with appropriate expertise and experience, such as the USNH General Counsel’s Office, the IO, and UNHInnovation staff. 

7.2.1   An Investigator's Significant Financial Interest is related to the Research (or, if required by the sponsor, related to the Investigator’s institutional responsibilities) when it can be reasonably determined that the Significant Financial Interest could be affected by the Research, or is in an entity whose Financial Interest could be affected by the Research.

7.2.2   An FCOIR exists when it can be reasonably determined that the Significant Financial Interest could directly and significantly affect the design, conduct, or reporting of the Research, or as otherwise defined by sponsor policy.

7.3   If an FCOIR exists, RIS shall propose a Management plan to the Investigator that details steps that may be taken to Manage, reduce, or eliminate the FCOIR. RIS may consult the Investigator, the DRC, the Investigator’s Department Chair, Dean/Director, or supervisor in the development of the proposed Management plan, including proposed conditions or restrictions to ensure that any conflict is Managed, reduced, or eliminated. Such conditions or restrictions may include, but are not limited to, any of the following:

7.3.1   Public disclosure of FCOIRs (e.g., when presenting or publishing the Research);

7.3.2   Monitoring of the Research by independent reviewers;

7.3.3   Modification of the planned activities (possibly subject to sponsor approval);

7.3.4   Disqualification from participation in all or part of the project;

7.3.5   Divestiture of Significant Financial Interests;

7.3.6   Severance of relationships creating conflict;

7.3.7   For Research involving human subjects, disclosure of FCOIRs directly to Research subjects; or

7.3.8   Any actions that may be required by an external sponsor of the related Research.

7.4   In all cases, resolution of the FCOIR or establishment of an acceptable FCOIR Management plan must be achieved before expenditure of any funds by the applicable Investigator under an award to UNH.

8.   Appeals

8.1   An Investigator may appeal the decision regarding the resolution or Management of the Investigator’s FCOIR to the UNH President, who may consult with the Investigator, the Investigator’s Department Chair, Dean/Director or supervisor, RIS, DRC, the VPRI, the IO, or any other parties that the UNH President deems appropriate. The UNH President will make a final determination, which shall be final and binding upon all parties.

8.2   This policy should not be construed to limit the rights of any member of the UNH community under applicable collective bargaining agreements and/or the University System of New Hampshire (USNH) Policy Manual.

9.   Compliance

9.1   As part of the Disclosure Statement, each Investigator must certify that if it is determined that an FCOIR exists, the Investigator will adhere to all conditions included in the FCOIR Management plan, and the Investigator will cooperate with any individual(s) responsible for monitoring compliance.

10.   Enforcement

10.1   Failure to adhere to this policy, or to properly disclose relevant Financial Interests, or to adhere to conditions in an FCOIR Management plan, will be considered a deviation from accepted standards of conducting Research at UNH.

10.2   RIS will investigate alleged violations of this policy and will make recommendations for action to the IO. Noncompliance with this policy may include: failure to file the necessary Disclosure Statements; knowingly filing incomplete, erroneous, or misleading Disclosure Statements; or failure to comply with conditions and procedures prescribed in an FCOIR Management plan. If the IO determines that the policy has been violated by an Investigator, they may propose to the VPRI sanctions including, but not limited to, notification to the sponsor or suspension/termination of the award; a letter to the Investigator's personnel file; and/or suspension of the Investigator’s privilege to apply for external Research funding.

11.   Records

11.1   The RIS office will maintain records of all Disclosure Statements and associated activities securely and confidentially (see section 6.4 of this policy for exceptions).

11.2   All such records will be maintained for a minimum of three years following termination or closeout of the award or resolution of any government action involving the records.

11.3   Records will not be routinely provided to sponsors unless a requirement, the sponsor submits a written request, or UNH is unable to satisfactorily Manage an actual or potential FCOIR. The IO will be responsible for communication with sponsors.