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Conflict of Interest and Outside Professional Activities

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Policy Information
  • Issue Date: December 10, 1997
  • Revision Date: August 25, 2015
  • Primary Contact: Research Administrator
  • Senior Administration: Deputy Director and Vice President for Research
  • Responsible Office: Deputy Director and Vice President for Research
Policy Statement
A conflict of interest (COI) can be any situation in which financial or other personal considerations have the potential to compromise a researcher’s professional judgment and objectivity in the design, conduct or reporting of research. This Policy is intended to ensure that all Scientific and Technical staff are free from the influence of personal considerations when representing the Institution, engaging in research, or making or providing public commentary. Further, the Policy requires that WHOI officers, Trustees, Scientific and Technical Staff, and administrators avoid or mitigate real or perceived financial conflicts of interest and ensure that their activities and interests do not conflict with their obligations to WHOI, to science, and to the public’s trust.

Reason for Policy

WHOI has a responsibility to ensure that it preserves the integrity of its research enterprise, the Institution as a whole, WHOI’s mission, and the public’s trust. Conflicts of interest or commitment, and misrepresentation are matters of concern to the Institution and they also carry further legal and regulatory implications. In particular, as the Institution is the administrator of sponsored research funds, it is obligated to ensure that such funds are used for the intended purpose and not for improper or inappropriate personal gain. This policy is to ensure that an individual's activities are in concert with the interests and mission of the Institution and that the Institution has sufficient information to arrive at a reasonable decision as to the appropriateness of activities.

Policy Information
Policy Statement
Reason for Policy
Who Should Be Familiar With This Policy
Related Documents
Definitions & Responsibilities

Who Should Be Familiar With This Policy
This policy applies equally to Institution personnel at all levels, defined as Trustees, members of the Administration, Scientific and Technical Staff, and all other employees, scholars, fellows, students, and others holding Institution appointments (hereafter collectively referred to as "Individuals" or "an Individual"). The Executive Vice President and Director of Research and the Vice President for Legal Affairs and General Counsel have been charged by the Institution's Director with administrative responsibility for this policy.

Related Documents

Institution Policies:

Conflict of Interest for Public Health Service Agencies (NIH, CDC, FDA)

Addendum to COI: PHS Financial Conflict of Interest (pdf)

Other Documents:

Examples of COI and COC

National Science Foundation (NSF) Conflict of Interest Policy for Investigators

AGU COI policy

Identifying and Addressing Individual Conflicts of Interest in Research

Institution training requirements

Training Registration Instructions: individuals with WHOI email

Training Registration Instructions: individuals without WHOI email


If you have questions about specific issues or need assistance with the interpretation of this policy, contact:

Executive Vice President and Director of Research

Vice President for Legal Affairs and General Counsel

Anyone affiliated with WHOI who has questions regarding compliance with this Policy in specific circumstances may contact the Office of the General Counsel for an advanced opinion.

Definitions & Responsibilities

These definitions apply to these terms as they are used in this policy.

Advisory Committee on Ethics, Conflicts, and Security (ACECS) 

WHOI’s Advisory Committee on Ethics, Conflicts, and Security (ACECS) promotes the principles of ethical research, the protection of national security interests, and their impact on WHOI’s mission and successful operation. As such, ACECS provides guidance to scientific and technical staff in the assessment and oversight of research ethics, conflicts of interest or commitment, intellectual property, and security in research and development projects at WHOI.

ACECS will review financial disclosures brought to their attention by Designees to determine whether a conflict of interest or commitment exists and determine what conditions or restrictions, if any, should be imposed to manage, reduce or eliminate conflict.

ACECS will be co-chaired by the General Counsel and Director of Research (DOR), and have seats for one member of the technical staff and two members of the scientific staff.  Additionally, the WHOI’s Security Officer, IT Director, the Director of Technology Transfer and an HR representative will have non-voting, ex-officio, membership.


Close relative(s)

Spouse and immediate family members.

Conflict of Commitment (COC)

Situations where an Individual's outside activities, however valuable in themselves, interfere or appear to interfere with their obligations to the Institution, colleagues, and students, and/or WHOI’s mission.


Conflict of Interest (COI)

Situations where an Individual might influence the Institution's business, research, or mission related activities in ways that could lead to personal gain or give improper advantage to themselves or close relatives.



Persons who are designated to review completed Conflict Disclosure forms prior to proposal submission and prior to Awards of sponsored projects. Designees will notify the ACECS of whether any reported Conflict of Interest would appear to be affected by a sponsored Project.

The Designees are the Department Chairs, Department Administrators, Department Administrative Professionals and all staff of Grant and Contract Services.

Financial Conflict of Interest (FCOI)

A financial interest for Individuals, or their close relatives, or for WHOI as an Institution, that WHOI reasonably determines could directly and significantly affect the design, conduct, or reporting of research.


Financial Interest

Anything of monetary value whether or not the value is readily ascertainable.  These include:

  • remuneration (e.g., salary, consulting fees, honoraria, paid authorship fees) from a publicly traded or a non-publicly traded entity,
  • equity interests (e.g., stocks, stock options or other ownership interest),
  • intellectual property rights (e.g., salaries, royalties),
  • reimbursed or sponsored travel.


Financially-Interested Company

An outside entity that funds, hires, or directs any operations, research, engineering development or management, or other services that could affect, reasonably appear to affect, or be affected by the conduct or outcome of a research project conducted at WHOI, and such project arises from or is directly connected to the funding company’s primary mission or business.



All personnel at WHOI including the Scientific and Technical Staff, Trustees, Administrative Staff and all other employees, students and post docs, and anyone who has a WHOI appointment including visitors, guests, Emeritus, and adjuncts. 


Industry-Sponsored research

Research directly funded by a corporate organization.



The principal investigator (PI), co-principal investigator, or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding.



Situations where an individual's outside activities, wittingly or unwittingly, permit others to construe that such outside activity is part of their activities and responsibilities as a member or representative of WHOI.



Any entity, or company, publicly or privately held, including Institution of Higher Learning or institute affiliated with Institutions of Higher Learning, Corporation, Federal, State or Local Government Agency, Foundation, non-profit or not-for-profit entities.


Public Health Service (PHS) Agency

Funding Agencies under the U.S. Department of Health and Human Services. These include NIH, FDA and CDC.

Significant Financial Interest



Any financial interest (see above) that reasonably appears to be related to the Individual’s responsibilities at WHOI and consists of one or more of the following interests of an Individual’s close relatives.

Types of significant financial interests are:

A. Remuneration and equities of a publicly traded entity that exceed $5,000 when aggregated in the 12 months preceding the disclosure of the SFI.

  1. Remuneration is salary and any payment for services not identified as salary (e.g., consulting fees, honoraria, paid authorship)
  2. Equities are stocks, stock options, or other ownership interests as determined through reference to public prices or other reason measures of fair market value.

Exempted is income from seminars, lectures, teaching engagements, service on advisory committees or review panels that are reimbursed or sponsored by a Federal, state, or local government agency, or other Organization.

Exempted is income from investment vehicles, such as mutual funds and retirement accounts, as long as the Individual (or the Individual’s close relative) does not directly control the investment decisions made in these vehicles.

B. Remuneration, as described above, from a non-publicly traded entity that exceeds $5,000 in the 12 months preceding the disclosure of the SFI, or when the Individual (or the Individual’s close relative) holds ­any equity interest (e.g., stock, stock options, or other ownership interests) in the entity.

Exempted is income from seminars, lectures, teaching engagements, service on advisory committees or review panels that are reimbursed or sponsored by a Federal, state, or local government agency, or other Organization.

Exempted is income from investment vehicles, such as mutual funds and retirement accounts, as long as the Individual (or Individual’s close relative) does not directly control the investment decisions made in these vehicles.

C. Intellectual property rights and interests (e.g., patents, copyrights, royalties) upon receipt of income related to such rights and interests that exceed $5,000.

Exempted are salaries, royalties, or other income paid by WHOI to the Individual if the Individual is currently employed or appointed by WHOI. This includes intellectual property rights assigned to WHOI and agreements to share in royalties related to such rights.


Standard Honorarium

Income from seminars, lectures, teaching engagements, service on advisory committees or review panels that are reimbursed or sponsored by a Federal, state, or local government agency, or other Organization.


WHOI Mission

The Woods Hole Oceanographic Institution is a private, independent, not-for-profit corporation dedicated to research and education to advance understanding of the ocean and its interaction with the Earth system, and to communicating this understanding for the benefit of society.


General Policy

In order to promote and protect academic freedom, and the integrity and the mission of the Institution, this policy is implemented to provide transparency and to ensure the resolution of any real, potential, or apparent COI or COC. The Policy provides and requires that WHOI officers, Trustees, Scientific and Technical Staff, and administrators avoid or mitigate real or perceived financial conflicts of interest and ensure that their activities and interests do not conflict with their obligations to WHOI, WHOI’s mission, to science, and to the public’s trust. Conflicts of Interest and Conflicts of Commitment can arise naturally from engagement with the world outside the Institution, and the mere existence of a COI or COC does not necessarily imply wrongdoing. However, both actual conflicts and the appearance of conflicts can be harmful to the Institution, WHOI’s mission, and to the Individual involved.

Disclosure and consultation continue to be the best means for avoiding conflicts of interest. Conflict of Interest and Conflict of Commitment situations are often complex and judgments may differ on whether or not a conflict, in fact, exists. Therefore, the goal of a policy of disclosure and consultation is to prevent Individuals from inadvertently placing themselves or the Institution in a position of conflict or apparent conflict.

The Institution requires that Individuals disclose certain financial interests, enabling WHOI to determine if a financial interest creates a conflict of interest or the appearance of a conflict of interest. A real or perceived conflict does not imply wrongdoing, and does not necessarily mean, for instance, that a researcher may not retain the financial interest and still undertake the affected research. Some conflicts must be eliminated, but often WHOI can work with the Individual to manage a conflict or the appearance of a conflict so that the activity can continue in a way that minimizes the possibility of bias and preserves objectivity. Proper management of a conflict depends on full and prompt disclosure. Further, the Institution recognizes that while an individual's primary professional commitment is to the Institution, outside consulting and other forms of independent work are accepted activities. Involvement in outside professional activities, both public and private, often serves not only the participant but the Institution and the field of ocean sciences as well.

A COI or COC may exist when an Individual has a personal economic or political interest to the extent that it affects, or provides an incentive to affect, the Individual’s performance. Further, any effort to influence the Institution’s work or direct its resources could be a potential conflict. This can arise when research is Industry-Sponsored or with a Financially-Interested Company. To maintain independence, the methods, processes, and conclusions must remain in the hands of the Individuals, with results or data to be made publicly available and/or subject to peer review.



If an actual, apparent, or potential COI or COC exists or develops, the affected Individual should fully disclose the relevant information to the greatest extent possible to his or her administrative supervisors, Department Chair, the Director of Research, or the General Counsel in advance and, unless the conflict is waived in writing by the Director of Research or General Counsel, abstain from acting on behalf of WHOI with respect to the matter in which he or she has a conflict.

Any Individual must seek review from either the Department, Chair, Supervisor, Director of Research or ACECS before engaging in activity that presents a potential conflict or appearance of a conflict or which calls into question the independence of the Individual or the Institution.

The duty of disclosure is ongoing and continuing. If an actual apparent or potential conflict of interest emerges or is revealed, disclosure should be made as soon as practical including, but not limited to, updating the Disclosure form.

The Conflict Disclosure form (form for Individuals with WHOI email / without WHOI email) must be completed and submitted sufficiently in advance of any anticipated agreement or other form of commitment, however informal, by the Individual to allow the appropriate individual(s) the opportunity to make inquiry as to the nature or extent of the activity, to reach a decision as to Institutional involvement, to require or suggest changes in or additions to any agreements or understandings that are to apply, and to explore patent possibilities, potential conflicts of interest or attention, and the like.

Any change since the last annual reporting period should be updated by submitting an updated Conflict Disclosure form.

Disclosures with issues or concerns will be reviewed by ACECS.


Who must disclose COI and COC?

All Individuals, as defined above, who have an apparent, potential, or real COI or COC.

Resident and Nonresident Guest Investigators, Visiting Scholars who received or are expected to receive more than $5000 from WHOI are required to file a WHOI Disclosure Form. All prospective employees, Guest Investigators and Visiting Scholars will receive this policy and a copy of the form when receiving an appointment at WHOI.

All Individuals who are listed as a Principal Investigator on a proposal or on an award must have submitted all relevant financial disclosures and have had COI training at the time that proposal is submitted to an Organization and at the time of the award.

Investigators receiving funding from Public Health Service must also report financial interest using the Addendum Financial Interest Report.


Who does not need to submit a Disclosure form?

Any MIT faculty who has a faculty appointment at WHOI and who is not receiving funding from a project at WHOI.

Director of Research in consultation with the General Counsel may, at their discretion, choose to exclude certain affiliates from this Policy.


What must be disclosed?

Individuals must disclose potential conflicts of interest or conflicts of commitment as discussed or found under the General Policy. Examples of COI and COC. Examples of COI and COC and Examples for ACECS review.

When in doubt, disclose.


Activities for ACECS Review


Supervisors or Departments can bring any activities or COI and COC concerns to ACECS for review. Any referral for COI or COC review and all significant COI and COC are reviewed and analyzed by ACECS for the DOR.

Examples of activities to review are

  • All projects involving Industry-Sponsored Research or with a Financially-Interested Company.
  • Outside consulting with a Financially-Interested Company.
  • Use of Institution facilities or equipment.
  • Participation by an Individual in commercial activities or industry.
  • Commitments of a professional or business nature of more than eighty hours per year, conducted during normal working hours, or that otherwise detracts from normal employment expectations or normal work hours.
  • Acceptance of compensation or perquisites if the amount received appears inconsistent with values of the service provided.
  • Service that involves remuneration, other than travel and incidental expense and Standard Honorarium, from any organization or individual  or individual from which the Institution currently receives or has received grants or other support, or with which the Institution has signed agreements or understandings.  
  • Service that benefits, directly or indirectly, an organization or Individual to which the Individual or a  close relative is indebted or obligated, or in which the Individual or a close relative is a partner, director, officer, employee, or share owner, or has other beneficial or creditor interest.
  • Projects with foreign governments or foreign nationals that involves National Security issues.
  • Work with industry partners that might lead to the creation of or exposure to WHOI Intellectual Property.


Corporate sponsorship, donations and naming request

Corporate sponsorship is a payment by a business to further WHOI’s mission.  ACECS will review all offers of or requests for corporate sponsorships of events, research, giveaways and other activities. ACECS will review any acknowledgement by WHOI of corporate sponsorship such as, the placement of corporate names and logos on WHOI websites, facilities, ships, publications, or other WHOI related items, and whether the acknowledgement is temporary or permanent. The goal of the review is to make sure that the sponsorship is aligned with WHOI’s mission and values, while also maintaining the integrity and independence of its science and our researchers. ACECS does not need to review the use of a corporate names in a factual news story or WHOI publications. 

Failure to comply with the Policy

Failure to comply with this Policy may result in sanctions, including a formal reprimand in an Individual’s personnel file, adverse impact on Individual’s evaluation and any potential raises, disclosure to federal agencies and/or the public, and termination of Individual’s employment or affiliate status. 


Financial Conflict of Interest Policy for Investigator Receiving Funds from Public Health Service Agencies

In addition to the WHOI Conflict Disclosure form to be submitted every year or when there is a change in an individual’s situation, Investigators who are funded by a Public Health Service Agency are required to take WHOI COC training every four years and be familiar with the WHOI Addendum to COI for PHS research, and, at least yearly, fill out the Addendum Financial Interest Report.

Regulations for PHS differ from WHOI and NSF COI and apply to all investigators who are involved in the design, conduct, or reporting of a PHS research project and applies to new proposal, new award, non-competing renewals and new no-cost extensions.

Regulations include

  • Broader disclosure requirement of all financial interests that relate to an individual’s institutional responsibilities, including remuneration from non-profit entities and sponsored travel.
  • Prior to submitting Public Health Service (PHS) (e.g. NIH, FDA, CDC) proposals or to dispersal of funds from PHS award, WHOI is required assure that all training and financial interest reports are up to date and completed, review and manage as necessary any financial conflict of interest, and report financial conflict of interest and management plan to the PHS agency.
  • WHOI is required to have policy and procedures that is in compliance with the PHS regulations.


Reporting by Individuals

All Individuals are required to report annually on all of their outside professional activities and to disclose significant financial interest in entities that would be affected by funded research. The Conflict Disclosure form (form for Individuals with WHOI email / without WHOI email) is to be submitted to the Supervisor,  Department Chair, Administrative Manager, Director of Research, Director, or Executive Committee of the Board of Trustees, as appropriate, not later than January 31st for the previous year's activities. If no activity has been performed, this should be so indicated on the Conflict Disclosure form.

If a conflict or potential arises between annual reporting, the Disclosure Reporting form must be updated. It is the duty of the Individual to keep the Disclosure Reporting form current and to update the form as needed during the year.

Any new employee or Individual newly affiliated with WHOI will fill out a Conflict Disclosure form at check-in or with their Department.


Institution's Training of Individuals

All Individuals at the Institution are encouraged to take the Institution's training* every 4 years.

The Intitution's training* every 4 years is required by the following Individuals:

Principal Investigators (this includes Scientists, Senior Technical Staff, and any other Individual named as a Principal Investigator on a proposal, contract, or an award).

All individuals involved in the design, conduct or reporting or proposed or awarded research from a Public Health Services Agency (e.g., NIH).

Department and Center Administrators and Administrative Professionals.

Directorate: all members.

All Directors and staff of the following:

    President and Director's Office

    Director of Research Office



    Finance & Accounting

    Grants and Contract Services

    Human Resources


    Office of Technology Transfer

Directors of:

    Environmental Health & Safety

    Facilities and Services

    Information Services

Administrative staff of Marine Operations

All members of ACECS

The Institution's training is also required immediately under the designated circumstances.

  • The Institution changes the Conflict of Interest and Conflict of Commitment policies in a manner that affects an Individual's requirements.
  • A Principal Investigator is new to the Institution.
  • The Institution finds that an Individual is not in compliance with the Institution's Financial Conflict of Interest policy or management plan.

 * Training registration instructions: Individuals with WHOI email / Individuals without WHOI email


Review of COI

Any referral of COI and COM are reviewed and analyzed by ACECS. The annual Conflict Disclosure form and updated disclosures may be reviewed by the ACECS. ACECS will reference NSF, NIH, AGU, and other principles of scientific integrity in making its review and determinations

In the event that a COI or COC determination is made by ACECS, it will be reported in writing to the Director of Research The Director of Research makes the determination in writing to the affected employee(s), with a copy to the Director. In addition, ACECS will inform any and all appropriate Institution offices and departments of this action, along with any restrictions and/or conditions that have been imposed as a consequence. Such offices could include, but not be limited to, Controller's, Procurement, Human Resources, and Grant and Contract Services.

Individuals must work with the Director of Research and the General Counsel to identify, disclose and satisfactorily resolve conflicts of interest when they arise.

The Director of Research and/or the General Counsel may, when necessary, confer with the Audit and Risk Committee of the Board of Trustees about the satisfactory resolution of conflicts of interest or conflicts of commitment when they arise.


Examples of Conflict Mitigation

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate COI or COC 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 research that would be affected by significant financial interests;
  5. divestiture of significant financial interests; or
  6. severance of relationships that create conflicts.

Appeal of Conflict Determinations

If an Individual elects to appeal the action taken by the Director of Research. The Director will conduct an independent review and his/her determination shall be binding. The Director has the ultimate authority and responsibility to determine when the foregoing policy applies and what steps, including procedural enforcement and sanctions, should be taken to correct a situation deemed not in the best interests of the Institution.


Record Retention

The Director of Research Office is responsible for forms and will retain all disclosures, conflict management plans, and related documents. Records of financial disclosure and of all actions taken to resolve COI will be kept for at least three years beyond the termination of the grant or contract to with they relate or until resolution of any Organization action involving those records, whichever is longer.


Agency Reporting

The Director of Research Office is responsible for reporting to an agency if it is unable to satisfactorily manage a conflict of interest.


Conflict Disclosure form for WHOI employees and Individuals with WHOI email and LDAP password

All Individuals with WHOI email and LDAP password must submit annually the Conflict Disclosure Reporting Form found on the link. The form must be updated and resubmitted as needed during the year.

Conflict Disclosure form only for Individuals without WHOI email and LDAP password

Link for Conflict Disclosure form for those Individuals without WHOI email and LDAP password. This link will not open the Disclosure form for those individuals with WHOI email and LDAP.

Financial COI for Public Health Services

Financial Conflict of Interest Report to be submitted yearly by all personnel involved with projects that are funded by Public Health Services Agencies (e.g., NIH, FDA, CDC)

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Last updated: March 16, 2017

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