Definitions
Each Investigator must disclose Significant Financial Interests (SFIs), and, for proposals submitted to NIH and other Publich Health Service agencies, third party Sponsored/Reimbursed Travel that occurred during the twelve-month period preceding the date of proposal submission. During the pendency of the proposal and ensuing award period, newly identified SFIs and/or changes in previously disclosed SFIs, and third party Sponsored/Reimbursed Travel, must be disclosed within 30 days from the date of SFI identification or relevant travel trip(s).
1. Significant Financial Interest
A Financial Interest held by an Investigator and/or an Investigator's Dependent* that reasonably appears to be related to the Investigator's Institutional Responsibilities and that consists of one or more of the following:
- Remuneration (including salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, and/or an Equity Interest held in such publicly traded company, if the aggregate value of such remuneration, plus the value of the Equity Interest as of the date of disclosure, exceeds $5,000.
- Remuneration (including, but not limited to, salary, consulting fees, honoraria, paid authorship and travel reimbursement) received from a non-publicly traded company during the twelve-month period preceding the date on which an Investigator is making a disclosure, if the remuneration exceeds $5,000.
- More than five percent Equity Interest or ownership in a publicly traded company or business.
- Any Equity Interest in a non-publicly traded company or business, regardless of value.
- Any Intellectual Property Rights, regardless of value, upon receipt of income related to such rights and interests.
- Income from a foreign institution of higher education or the government of another country (including local, provincial or equivalent governments of another country).
- When applied to sponsored project applications (proposals) submitted to and/or awards received from a Specified Sponsor, any reimbursed or sponsored travel (i.e., travel that is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), provided that the travel is not reimbursed or sponsored by a federal, state or local government agency within the U.S.; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); or an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education in the U.S. The travel disclosure must include, at minimum, the purpose of the trip, identity of the travel sponsor/organizer, travel destination, travel duration, and monetary value.
- When applied to sponsored project applications (proposals) submitted to and/or awards received from U.S. federal sponsors, participation in any Foreign Talent Recruitment Program, regardless of the type, amount, or ostensible lack of remuneration.
Significant Financial Interest does not include:
- An Employee's salary, royalties or other remuneration received from the University and/or the Purdue Research Foundation.
- Income from seminars, lectures or teaching engagements sponsored by a federal, state or local government agency within the U.S.; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); or an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education in the U.S.
- Income from service on advisory committees or review panels for a federal, state or local government agency within the U.S.; a U.S. institution of higher education as defined at 20 U.S.C. 1001(a); or an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education within the U.S.
- Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
*Dependent:
An Employee's or Investigator?s spouse or unemancipated child(ren), including stepchildren and adoptees, under the age of 18, or anyone who receives more than one-half of their financial support during a year from an Employee.
Foreign Talent Recruitment Program:
Any effort to recruit science and technology professionals or students that is organized, managed or funded by a foreign government (national, provincial, or local), a foreign government instrumentality or entity, or an entity based in, funded by, or affiliated with a foreign country, whether or not directly sponsored by the foreign country. Some Foreign Talent Recruitment Programs operate with the intent to import or otherwise acquire from abroad, sometimes through illicit means, proprietary technology or software, unpublished data and methods, and intellectual property to further the military modernization goals and/or economic goals of a foreign government. Many, but not all, programs aim to incentivize the targeted individual to relocate physically to the foreign state for the above purpose. Some programs allow for or encourage continued employment at United States research facilities or receipt of federal research funds while concurrently working at and/or receiving compensation from a foreign institution, and some direct participants not to disclose their participation to United States entities. Compensation could take many forms including cash, research funding, complimentary foreign travel, honorific titles, career advancement opportunities, promised future compensation, or other types of remuneration or consideration, including in-kind compensation.
2. Institutional Responsibilities
An Employee or Investigator's professional responsibilities on behalf of Purdue, including, but not limited to, activities such as research, research consultation, teaching, professional practice, institutional committee memberships and service on panels such as institutional review boards or data and safety monitoring boards. Institutional Responsibilities are those activities that fall within the scope of Total University Effort as defined in the policy on Effort Reporting (II.C.1) and which are not Reportable Outside Activities as defined in the policy on Conflicts of Commitment and Reportable Outside Activities (III.B.1).
3. Reimbursed/Sponsored Travel that needs to be disclosed:
Any reimbursed or sponsored travel (i.e., travel that is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), provided that the travel is not reimbursed or sponsored by a federal, state or local government agency, an institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
4. Third Party
A third party is an Entity (Company/Organization) other than Purdue or one of the following: a federal, state or local government agency, an American institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education.
Travel sponsored or reimbursed by Purdue or a federal, state or local government agency, an American institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education DOES NOT NEED TO BE DISCLOSED.