VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U015

Sanctions and corrective actions will be communicated in writing to the VCOM personnel, and others as appropriate, and will also include the details of the compliance failure. The VCOM personnel will be required to agree to the sanctions and corrective actions in writing. Depending upon the severity of the non-compliance, potential sanctions may include: • Education and training • Requirement of the Institutional Integrity Officer’s review of the VCOM personnel’s outside activities more often (e.g. every six months) • Formal admonition • A letter in the VCOM personnel’s file indicating that the individual’s good standing as a member of VCOM has been called into question • If the non-compliance involve research, restriction of access to all project and/or overhead funds and/or removal of the VCOM personnel from having further involvement in the applicable research • Ineligibility of the VCOM personnel to apply for grants, IRB approval or supervision of students or trainees • Requirement of the VCOM personnel to write the editor of the journal indicating the non compliance • Ongoing monitoring of the affected research and/or the VCOM personnel’s other research activities • Independent monitoring of manuscript submissions • Other potential employment sanctions as determined by the applicable Associate Dean and the Dean • Non-renewal of contract or termination of employment. VCOM will comply with federal financial conflict of interest requirements regarding non-compliance retrospective review and corrective action (see the VCOM Financial Conflict of Interest in Research Policy). Appeals made by the VCOM Personnel on the determination of non-compliance and subsequent sanctions will follow the procedure as outlined in the VCOM Faculty Handbook . 10. DURATION OF POLICY The Policy on Conflicts of Interest and Industry Relationships is established by the Research Department and is effective as of the date above and shall remain effective until amended or terminated by the President.

VCOM Policy on Conflicts of Interest

Page 11 of 11