Definitions -- Financial Disclosure Policy

Conflict of Commitment:
a potential or actual conflict of commitment exists when commitments and obligations to consulting, research, and other scholarly activities require the individual to perform work or activities during time that the individual is expected to perform services for the University.
Conflict of Interest:
exists if the reviewer(s) of disclosures determines that a significant financial interest could directly and significantly affect the design, conduct, or reporting federally funded activities. Examples of conditions or restrictions that might be imposed to manage, reduce, or eliminate conflicts of interest include, but are not limited to:
  1. Public disclosure of significant financial interests;
  2. Monitoring of research by independent reviewers;
  3. Modification of the research plan;
  4. Disqualification from participation in the portion of the federally funded research that would be affected by the significant financial interests;
  5. Divestiture of significant financial interests; or
  6. Severance of relationships that create conflicts.
Investigator:
principal investigator or any other person who is responsible for the design, conduct, or reporting of a research project funded by the federal government or proposed for such funding.
Members of Immediate Family:
the investigator's or faculty members spouse, dependent children, parents, parents-in-law, siblings or other relatives living at the same address as the investigator or faculty member.
Records:
all financial disclosures and all written documentation on action taken by the Institution to manage conflicts of interest shall be retained until three(3) years after the later of the termination or completion of the award to which they relate, or the resolution of any government action involving those records.
Reviewer:
a person or persons designated by the institution to review financial disclosures, determine whether a conflict of interest exists, and determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce, or eliminate such conflict of interest.
Significant Financial Interest:
anything of monetary value, including but not limited to: salary or other payments for services(e.g., consulting fees or honoraria); equity interests(e.g., stock options or other ownership interests); and intellectual property rights(e.g., patents, copyrights and royalties from such rights). The term does not include:
  1. salary, royalties, or other remuneration from Western Washington University;
  2. income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
  3. income from service on advisory committees or review panels for public or nonprofit entities;
  4. an equity interest that when aggregated for the investigator and the investigator's spouse and dependent children, meets both of the following tests: does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a five(5) percent ownership interest in any single entity; or salary, royalties, or other payments that when aggregated for the investigator and the investigator's spouse and dependent children over the next twelve months are not expected to exceed $10,000.
Page Updated 12.12.2011