• Policy Requirements:  Auburn University intends "to manage financial conflicts of interest of its employees as part of ongoing efforts to prevent outcomes that may be harmful to sponsored activities, operation of regulatory compliance committees, technology transfer efforts, or the University at large. Therefore, employees responsible for the design, conduct or reporting of Sponsored Research, engaging in Technology Commercialization, and/or Related Activities (Affected Employees) must report Significant Financial Interests and must work with the University to develop a plan to Manage Financial Conflicts of Interest as necessary." (AU FCOI Policy for Research and Related Activities. Approved by Act of the University Senate, January 13, 2015.)
  • Policy Principles:
    • "The integrity of the University as a community of scholars requires the open exchange of ideas in an atmosphere free from financial conflict and undue influence. This is especially important in those cases where relationships with external parties could lead to circumstances adversely impacting scholarly work, integrity, judgment or the conduct of sponsored activities." (FCOI Policy)
    • "Auburn acknowledges that Affected Employees and their Immediate Family have the right to acquire personal financial assets and to establish financial relationships with outside entities. However, Affected Employees also have the responsibility to manage their financial affairs and relationships in a manner that does not interfere with, or improperly influence, the performance of their professional duties and responsibilities. As long as Significant Financial Interests are disclosed and financial conflicts are managed, reduced, or eliminated; they need not be a problem." (FCOI Policy)
  • Primary Goal:  AU adopted the FCOI Policy "to ensure that faculty and other employees are made aware of [FCOIs], are dutiful in internally disclosing Financial Interests, and that identified conflicts receive scrupulous attention and management." (AU Procedures for FCOI Policy for Research and Related Activities. Approved by Act of the University Senate, January 13, 2015.)
  • Applicability: The AU FCOI Policy requires disclosure of significant financial interests to the University at certain times by "Affected Employees," defined by involvement in:
  1. Sponsored Research: "Faculty (as outlined in the Faculty Handbook) and other employees responsible for the design, conduct or reporting of sponsored Research....This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)
  2. Technology Commercialization: "Faculty (as outlined in the Faculty Handbook) and other employees....engaged in technology commercialization activities. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)
  3. Related Activities: "Faculty (as outlined in the Faculty Handbook) and other employees....engaged in any activity which has the potential to improperly influence sponsored Research or Technology Commercialization. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students." (FCOI Procedures)

• Principal Investigator Training and Disclosure Oversight Responsibilities.
  • Continuing Responsibilities. On a timely basis, from the proposal stage throughout the duration of a project subject to the FCOI regulations, Principal Investigators are responsible for:
    1. Identifying Investigators on a proposal, award and modification to the scope of work, and
    2. Ensuring Investigators take FCOI Training (PHS and DOE awards) and submit FCOI Disclosure Questionnaires (all awards).
  • The PI, Co-PI, PD, Co-PD and Senior/Key Personnel named in the proposal for funding, the award, a progress report or an award modification or in a subaward, subgrant, subcontract are always considered an Investigator.

• COI Checklist 
  • Prior to expending any funds under a sponsored research project:
  1. All Investigators must have a current (within the last 12 months) COI disclosure in Endeavor.
  2. All Investigators must have current COI training if the award is from a PHS or DOE Agency.
  3. All Investigators with COIs must have an approved COI management in place.
  4. If applicable, the Principal Investigator must confirm that all sub-recipients have certified COI compliance. 

• Sponsored Research: PI Disclosure Oversight Responsibilities.
  • Continuing Responsibilities: On a timely basis, from the award stage throughout the duration of a research project subject to the AU FCOI Policy, Principal Investigators are responsible for:
  1. Identifying Affected Employees on a sponsored research award, and
  2. Ensuring Affected Employees submit FCOI Disclosure Questionnaires.
  • Who is an Affected Employee engaged in Sponsored Research? Consult the Guide to Identifying Affected Employees Subject to the AU FCOI Policy to determine which persons on a sponsored research project are Affected Employees.
    • The PI, Co-PI, PD and Co-PD named in the proposal for funding, the award, a progress report or an award modification or in a subaward, subgrant or subcontract are always considered an Affected Employee.

• Technology Commercialization: Affected Employee Disclosure Questionnaire Filing Responsibilities.
  • Continuing Responsibilities: On a timely basis, when planning to participate (and definitely before participation) in Technology Commercialization activities subject to the AU FCOI Policy throughout the duration of the Technology Commercialization activities, Affected Employees are responsible for submitting FCOI Disclosure Questionnaires. 
  • Who is an Affected Employee Engaged in Technology Commercialization Activities? 
  1. AU Employee. The AU FCOI Policy applies to "Faculty (as outlined in the Faculty Handbook) and other employees.... engaged in technology commercialization activities. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students."
  2. Engaged in Technology Commercialization Activities. You are engaged in "Technology Commercialization" activities if you plan to or participate in the "marketing, licensing, or conveyance of rights to intellectual property, technology, and know-how into the private market."

Multiple Research Sponsors: 

• If you have multiple funding sponsors, you do not need to submit multiple disclosure questionnaires at the same time and/or for the same purpose.
• Depending on the requirements of your multiple funding sources and/or AU policy, however, you may need to revise/recertify your disclosure one or more times. See COI/COC webpages for revision/recertification requirements.
• For example, if you are PHS Investigator and have submitted an annual disclosure questionnaire, you need not submit a completely new disclosure questionnaire upon receiving an award from a private sponsor. However, if your significant financial interests have changed since your most recent annual disclosure, you must revise the disclosure to ensure that the information is accurate and complete; this enables timely management, reduction or elimination of any potential, perceived or actual financial conflict of interest.

• Related Activities: Affected Employee Disclosure Questionnaire Filing Responsibilities.
  • Continuing Responsibilities: On a timely basis, when planning to participate (and definitely before participation) in Related Activities subject to the AU FCOI Policy and throughout the duration of the Related Activities, Affected Employees are responsible for submitting FCOI Disclosure Questionnaires. 
  • Who is an Affected Employee Engaged in Related Activities?
  1. AU Employee. The AU FCOI Policy applies to "Faculty (as outlined in the Faculty Handbook) and other employees.... engaged in Related Activities. This could include, but is not limited to, tenure and non-tenure track faculty, post-doctoral fellows, and/or graduate students. 
  2. Engaged in Related Activities. You are engaged in "Related Activities" if you plan to or participate in "any undertaking which has the potential to improperly influence sponsored Research or Technology Commercialization. Examples include, but are not limited to: equity interest in or remuneration from a non-publicly traded entity or providing outside services of a professional nature."

• When to Disclose: 
  • Annually
    • Full-time Auburn employees:  As of October 2019, full-time employees are required to complete an annual disclosure. Disclosures comprise significant financial and other interests that reasonably relate to the employee's institutional responsibilities and should be updated annually and within 30 days of discovering any new interest or relationship.
    • Auburn students:  Please contact research.integrity@auburn.edu if you need to submit a disclosure.
    • External individuals:  Please contact research.integrity@auburn.edu if you need to submit a disclosure.

• How to Disclose: Starting January 2024, Auburn University introduced a new electronic research administration and compliance system. All annual disclosures must now be submitted online through the Endeavor platform.​
  • New Endeavor Users.
    • Helpful Guide for Auburn employees:  Resources, Videos, and FAQs are available to help you access your Endeavor account, log in, and complete your Disclosure Profile. 
    • Auburn students:  Please contact research.integrity@auburn.edu if you need to submit a disclosure.
    • External individuals:  Please contact research.integrity@auburn.edu if you need to submit a disclosure.
  • ​Accessing previous disclosures.​
    • Access to COI-SMART ends March 2024. To save a copy of your previous disclosure, log in to COI-Smart, click on "My Questionnaires," select the most recent submitted questionnaire, scroll down, and either select "Email Responses" or "Download with All Responses." COI-Smart will not be active after March 31, 2024.

• When and How to Train: Online via CITI. 
  • Certain research sponsors require FCOI training. See the PHS FCOI webpage for training required by Investigators subject to the FCOI Regulations.
  • Voluntary Conflict of Interest training is available to all researchers and strongly encouraged by the University. Consult the Guide for Taking Financial Conflict of Interest Training.