The following disclosure requirements are intended to elicit the basic information the University needs to determine whether a person has an actual or apparent conflict of interest, as detailed in Section B above. More detailed information may be requested and required by the Conflict of Interest Officer to ensure the appropriate consideration and resolution of any such actual or apparent conflict of interest.
1. Initial Disclosure
All (1) FACULTY; (2) STAFF who are responsible for (i) the procurement, exchange, or sale of goods, services, or other assets; (ii) the negotiation or formation of contracts or other commitments affecting the assets or interests of the University; (iii) the rendering of professional advice to the University; or (iv) managerial, supervisory, or advisory functions related to the conduct of SPONSORED PROGRAMS; and (3) INVESTIGATORs are required to complete and submit a disclosure form upon their employment by the University.
2. Annual and Updated Disclosures
All INVESTIGATORs are required to submit a disclosure form on an annual basis during the pendency of an award. In addition, all persons whose initial or subsequent disclosure reveals an actual or apparent conflict of interest are required to submit disclosure forms on an annual basis until relieved of that obligation by the appropriate Conflict of Interest Officer. All persons identified in Section C.1 of the Policy are also required to submit revised forms at any point at which their most recent disclosure becomes incomplete or inaccurate (e.g., if a SIGNIFICANT FINANCIAL INTEREST arises or changes, a research activity commences, a funding application is submitted, or the person’s University authority or influence changes). With the approval of the University Conflict of Interest Committee (see Section D.2 of the Policy), each campus and University Services area of the University will develop a procedure to notify FACULTY, STAFF, and INVESTIGATORs annually of their reporting obligations. Specific information regarding the reporting procedures for each campus and University Services area may be accessed at http://policies.georgetown.edu/conflictofinterest.
3. Disclosure Form
Disclosures shall be made on a form or in a format approved by the University Conflict of Interest Committee. While all such forms must meet the requirements set forth in the Policy, the three campuses and University Services may, with the Committee’s approval, use different forms and formats for the purposes of the reporting required under this Policy. All disclosure forms will require individuals identified in Sections C.1 and C.2 of this Policy to disclose any activities or relationships described in Section B of the Policy. INVESTIGATORs must additionally make disclosures in accordance with Appendices B and C of the Policy.
Disclosure forms will be considered strictly confidential, to the extent permitted by law, and the information on the disclosure forms will be shared only with those who have a need to know under this Policy and/or applicable law. The appropriate Office of the Executive Vice President, Vice President, or Director, as the case may be under Section D.1 of the Policy, will establish procedures for maintaining and preserving confidentiality. Completed disclosure forms will be forwarded to the appropriate Conflict of Interest Officer designated under Section D.1 of the Policy. INVESTIGATORs must provide any required disclosures to the appropriate designated individual prior to the submission of an application to PHS (including the National Institutes of Health) or the National Science Foundation (“NSF”) and as provided in Appendices B and C of the Policy.
a. Disclosure of Ownership Interest or Executive Position
When the disclosure required is a disclosure of an ownership interest or of an EXECUTIVE POSITION, the disclosure must contain the following information, when applicable:
(1) the name and address of the BUSINESS and a general description of the BUSINESS;
(2) a statement of the fair market value of the investment or interest held described in broad categories similar to that on Federal disclosure forms;
(3) a statement indicating whether the interest, when aggregated for the person and his or her FAMILY, represents more than five percent of total ownership in the entity; and
(4) the position held in the BUSINESS by the person.
b. Disclosure of Income, Fees, Loans or Other SIGNIFICANT FINANCIAL INTERESTS
When the disclosure required to be given is of income, fees, loans or other sums, the disclosure shall include the following information, when applicable:
(1) the name and address of the BUSINESS and a general description of the BUSINESS activity;
(2) a statement of the aggregate annual amount of income/compensation received from the BUSINESS described in broad categories similar to that on Federal disclosure forms;
(3) in the case of a loan, the annual interest rate, the security, the terms for repayment and the names of any guarantors.