The document, authored by COGR and published in 2001, outlines foundational considerations for defining and addressing institutional conflicts of interest (ICOI) within research institutions, primarily universities. It adopts and expands upon definitions provided by the Association of American Universities (AAU), distinguishing between individual and institutional conflicts. An institutional conflict is described as involving situations where the organization, its senior personnel, or affiliated entities hold financial interests or external relationships that could directly or indirectly compromise—or appear to compromise—the integrity of research activities or other core missions. These conflicts may emerge when the institution enters into relationships with commercial sponsors, invests in start-up companies, benefits from major gifts, or engages in joint ventures and master agreements, especially when these interactions intersect with faculty research and decision-making.
The document provides a detailed exploration of typical scenarios that may present institutional conflicts, such as accepting significant gifts from commercial sponsors, holding equity or financial interests in entities licensing university technology, managing long-term research agreements, conducting human subjects research, procuring goods from vested firms, and participating in economic development activities. It further discusses the special responsibilities of trustees, officers, and employees whose roles might inadvertently promote or create perceived conflicts. The guidance emphasizes that not every described scenario will necessarily constitute a conflict, but collectively, these examples inform the need for comprehensive policy development. The central recommendation is for universities to systematically review potential sources of institutional conflicts to inform policy creation and management, ensuring that institutional missions and values remain uncompromised by financial interests or extramural relationships.
