VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U015

9. ENFORCEMENT AND SANCTIONS .................................................................................................... 10 9.1 Enforcement and Monitoring........................................................................................................................10 9.2 Assessing Non-Compliance and Sanctions ..................................................................................................10 10. DURATION OF POLICY .................................................................................................................... 11 1. PURPOSE The Edward Via College of Osteopathic Medicine (VCOM) Policy on Conflicts of Interest provides guidelines for interactions between VCOM and its faculty, staff and students with private industry. The goal of this policy is to increase transparency of industry interactions and to eliminate or mitigate conflicts of interest created by these interactions. These guidelines will help guarantee VCOM’s academic integrity and promote and safeguard the interests and reputation of VCOM and its faculty. VCOM encourages employees to engage in appropriate outside relationships; however, employees of the College are expected to avoid conflicts of interest that have the potential to affect the College’s interests, compromise objectivity in carrying out College responsibilities or otherwise compromise performance of College responsibilities. A conflict of interest does not imply that the conflict is unethical or impermissible; it means that the relation of the conflict to the individual’s College responsibilities must be carefully examined. Conflicts, real or perceived, may impair performance of VCOM’s mission of teaching, research and public service, as well as jeopardize public trust and support. All VCOM personnel must become familiar with this policy and are expected to understand and adhere to it. Any questions regarding conflicts of interest, or this policy should be forwarded to the Office of Research Administration. Therefore, all VCOM employees must disclose, for review and approval, all potential conflicts of interest and all actual or perceived conflicts of interest prior to engaging in any activity by which the VCOM employee may benefit financially or through investment. 2. DEFINITIONS Conflict of Interest: Any situation in which an individual is in a position to exploit his/her professional or official capacity in some way for personal benefit. A potential conflict of interest occurs when there is a divergence between the VCOM personnel’s private interests and his/ her professional obligations to the College such that an independent observer might reasonably question whether the individual’s professional actions or decisions are determined by considerations of personal gain, financial or otherwise. An actual conflict of interest is situation dependent and not necessarily determined entirely by the character or actions of any one individual. Disclosure: Full specification of the VCOM personnel’s relationship with an external organization or involvement in external activities. Industry: The pharmaceutical, medical device and biotechnology industries and their representatives.

VCOM Policy on Conflicts of Interest

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