Pursuant to IIT’s Investigator Conflict of Interest and Conflict of Commitment Policy (the “Policy”), all Investigators are required, on an annual basis, to disclose certain significant financial interests using this electronic Disclosure Form.  Further, all Investigators have an on-going obligation to submit an updated Disclosure Form within 30 days of discovering or acquiring (e.g., through purchase, marriage, inheritance) a new significant financial interest.  Finally, by submitting this Disclosure Form, Investigators are acknowledging that they have read and understand the Policy and agree to abide by it.  

<strong>Because of federal regulatory requirements, IIT cannot, and will not, submit any proposals on an Investigator’s behalf or allow an Investigator to expend any funds for research projects funded by an Awarding Component if he or she fails to fully and accurately complete and submit this Disclosure Form and comply with the Policy.</strong>

Under the Policy, the terms “Investigator” and “significant financial interest” are defined as follows:

Investigator means the project director or principal investigator and any other person, regardless of title or position, who is, or has been within the preceding 24 months, responsible for the design, conduct or reporting of funded research, or proposed for funding, which may include, without limitation, all full-time faculty members, collaborators, consultants and visiting and part-time faculty members with research privileges, but excludes visiting and part-time faculty members who only provide classroom instruction. Senior/key personnel, as such term is defined in the Policy, are deemed to be Investigators.

Significant financial interest means:
(A) A financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator’s spouse and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities:

(1) With regard to any publicly traded entity, a significant financial interest exists if the value of any remuneration received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, when aggregated, exceeds $5,000.  For purposes of this definition, remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid authorship); equity interest includes any stock, stock option or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;

(2) With regard to any non-publicly traded entity, a significant financial interest exists if the value of any remuneration (as defined in (1) above) received from the entity in the twelve months preceding the disclosure, when aggregated, exceeds $5,000, or when any equity interest (e.g., stock, stock option, or other ownership interest) is held; and

(3) Intellectual property rights and interests (e.g., patents, copyrights) upon receipt of income related to such rights and interests that, when aggregated, exceed $5,000.  Unlicensed, non-income generating intellectual property is excluded.

(B) Any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) related to their institutional responsibilities; excluding travel that is reimbursed or sponsored by (1) a Federal, state, or local government agency, (2) an institution of higher education as defined at 20 U.S.C. 1001(a), or (3) an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education.  With respect to such travel, the Investigator will need to disclose, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination and the duration.  Additional information, such as a determination or disclosure of monetary value, may be requested if needed in order to determine whether the travel constitutes an FCOI with respect to a funded research project.

(C) Significant financial interest does not include the following: (1) salary, royalties or other remuneration paid by IIT to the Investigator if the Investigator is currently employed or otherwise appointed by IIT, including intellectual property rights assigned to IIT and agreements to share in royalties related to such rights; (2) 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; and (3) income from seminars, lectures or teaching engagements sponsored by (a) a Federal, state, or local government agency, (b) an institution of higher education as defined at 20 U.S.C. 1001(a), (c) an academic teaching hospital, medical center or research institute that is affiliated with an institution of higher education; or (d) income from service on advisory committees or review panels for any such entity set forth in (a) - (c).

Other relevant terms are defined in the Policy.  Accordingly, please refer to the Policy when completing this Disclosure Form.

You may send any additional documents to the Office of General Counsel at rabed@iit.edu.  If further information is required to complete any conflict analysis, the Office of General Counsel will contact you.

When completing this Disclosure Form, please note that “I” includes you, your spouse and dependent children. All amounts referred to are in the aggregate. For example, if you have one arrangement with an entity for a scientific advisory board position for $3,000 and your spouse has an arrangement with the same entity as part of a speaker’s bureau for $3,000, the aggregate amount received from the entity exceeds the $5,000 threshold, and these arrangements must be reported.