Conflict of Interest/Financial Disclosure for Sponsored Projects Policy


Office of Sponsored Programs


Director, Office of Sponsored Programs


Research and Sponsored Programs



Effective Date:


Review Date:


Implementation History:



Conflicts of interest, financial disclosure, Research Foundation, federal grants

Background Information:

Annual financial disclosures are a requirement for all federal grants and contracts. As of August 24, 2012, this policy applies to all federal agencies except those under the Public Health Service which have a separate policy.


In order to maintain the integrity of its federally funded projects, Empire State College has the responsibility to manage, reduce, or eliminate any actual or potential conflicts of interest that may be presented by the personal financial interests of a faculty or staff member who is involved in the design, conduct, and/or reporting of a sponsored project and their immediate family members.


Research Foundation - As used in this policy, the term shall mean the Research Foundation of the State University of New York.

“Officer” and “employee” – Shall include any person representing or acting on behalf of the Research Foundation in any capacity in a sponsored program or project administered through the Research Foundation.


The Rule with Respect to Conflicts of Interest:

No officer or employee should have any interest, financial or otherwise, direct or indirect, or engage in any business or transaction or professional activity or incur any obligation of any nature, which is in substantial conflict with the proper discharge of his/her duties in the best interests of the Research Foundation.

No officer or employee should have any financial interest that will, or may be reasonably expected to, bias the design, conduct, or reporting of sponsored programs.


  1. No officer or employee should accept other employment, which will impair his/her independence of judgment in the exercise of his/her duties and responsibilities.
  2. No officer or employee should accept employment or engage in any business or professional activity, which will require him/her to disclose confidential information, which he/she has gained by reason of his/her position or authority.
  3. No officer or employee should disclose confidential information acquired by him/her in the course of his/her duties except as required by law nor use such information to further his/her personal interests, unless such information has previously been made public.
  4. No officer or employee should use or attempt to use his/her position to secure privileges or exemptions for himself or herself or others.
  5. No officer or employee should engage in any transaction with any business entity in which he/she has a direct or indirect financial interest that might reasonably tend to conflict with the proper discharge of his/her duties or responsibilities.
  6. An officer or employee should not by his/her conduct give reasonable basis for the impression that any person can improperly influence him/her or unduly employ his/her favor in the performance of his/her duties, or that he/she is affected by the kinship rank, position or influence of any party or person.
  7. An officer or employee should abstain from making personal investments in enterprises which he/she has reason to believe may be directly involved in decisions to be made by him/her or which will otherwise create conflict between his/her duties in the best interests of the Research Foundation and his/her private interest.
  8. An officer or employee should pursue a course of conduct which will not raise suspicion that he/she is likely to be engaged in acts that are in violation of his/her trust. 


An Annual Disclosure of Financial Interests must be completed by project directors who receive federal funds. The Disclosure must be on file at the time the proposal is submitted and must be completed at least annually for as long as project remains active or sooner if there is a significant change in the project director’s financial interests. Annual disclosures must be completed by October 1.

Disclosure Review:

The completed Annual Disclosure of Financial Interests must be submitted to the Director of Sponsored Programs for a preliminary review. All apparent conflicts of interest must be disclosed to the college’s President or designee for review and determination of whether a violation of this policy exists. Any determination by the college President or designee of a violation shall be forwarded to the President of the Research Foundation. 

Applicable Legislation and Regulations

National Science Foundation – 2 CFR, Part 215, National Institutes of Health – 42 CFR, Part 50, Subpart F,

U.S. Department of Education – 34 CFR, Part 74.3

Related References, Policies, Procedures, Forms and Appendices

Financial Disclosure Form

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