All University faculty, staff, and students who seek to take equity in a LSC and/or serve in a management or officer position, such as CEO, must sign a LSC Policy Compliance Statement (PCS).
Standard PCS Terms
The faculty member, staff member, or student signing a PCS will agree to the following standard terms:
- I will obtain approval from my supervisor and the COIC before entering into a new consulting relationship with the company or executing an amendment to an existing agreement and/or prior to accepting any management or officer role with the company (e.g., C-level positions, membership on the Board of Directors).
- I will inform my supervisor of any proposed interactions between the University of Pittsburgh and the company of which I am aware. I will disclose my University position and my relationships with the company in any negotiations between the company and the University. I may advise and participate indirectly in negotiations between the company and the University. If there are no officers of the company who are not also University employees, only a company attorney or other third-party contractor may negotiate any non-standard agreements between the University and the company.
- I understand that the COIC must prospectively approve any sponsored research agreements between the company and the University. If I wish to participate in a research project sponsored by the company, I must disclose my financial interest in the company to the Office of Research and agree to a CMP specific to the project developed by the COID.
- I understand that the company may not sponsor human subject research at the University if the University may benefit or be perceived to benefit financially from the outcome of that research, except in the case of compelling circumstances supporting a waiver of this prohibition. A request for a waiver, accompanied by a statement justifying the request, must be submitted to the COIC and generally will require approval by the Senior Vice Chancellor for Research. UPMC's Office of Sponsored Programs and Research Support (OSPARS) is not part of the University. Requests to conduct a company-sponsored, company-initiated clinical trial through OSPARS must be made to that office.
- I will contact the COID before engaging in University research that is of commercial interest to the company (e.g. research that is evaluating or further developing its intellectual property) so that a plan to manage my conflict of interest can be implemented.
- I will ensure that my related financial interest is disclosed in any IACUC or IRB protocols covering research that is sponsored by or of commercial interest to the company.
- I understand that I cannot be the PI of any human subject research protocol covering research that is sponsored by or of commercial interest to the company. I may participate as a co-investigator under a COI Management Plan.
- I will contact the COID before engaging in any new Public Health Service-funded research so that a determination can be made as to whether my relationship with the company gives rise to a Financial Conflict of Interest with such research.
- I will prospectively contact the COID for guidance if I wish to serve as the PI for the company of any research proposals submitted on behalf of the company (such as an SBIR or STTR proposal) or engage in research on behalf of the company, for example, under a consulting agreement.
- I will disclose my financial interest in the company in all abstracts, publications, presentations, and press releases involving research sponsored by the company or that is of commercial interest to the company.
- I will disclose my financial interest in the company in related applications or proposals to fund research of commercial interest to the company as directed by the funding source. If the instructions are unclear, I will contact the sponsor or agency for guidance.
- I will disclose my relationships with the company on MyDisclosures. If applicable, I will disclose receipt of royalties, milestone fees, or other proceeds from technology I developed that is optioned or licensed to the company when and if such payments exceed the relevant reporting threshold.
- [Full-time faculty members] I will not spend more than one day per week on the average of my University time on outside professional activities, including any current or future work for the company, over the period of my contractual appointment at the University and any summer months during which I receive compensation for teaching, research, or other University activities. I understand that my department chair or supervisor may further limit the amount of my University time that I may devote to outside activities by providing a written justification for the reduction.
[Staff] All of my work on behalf of the company will occur outside my normal working hours at the University.
- I will seek the approval of my department chair and/or other relevant supervisor for approval of any “Incidental Use” of University resources (as defined and described in sections II.H and III.E of Policy RI01) and I will not use any University or UPMC confidential data, funds, trademarks, or logos in performing current or future outside work for the company.
- I understand that any proposed use of University or UPMC facilities or resources by the company must be covered under an institutional agreement between the company and the University or UPMC.
- I will not participate in any University or UPMC purchasing decisions regarding the company’s products or services.
- I understand that the COIC must prospectively approve all consulting or employment agreements, whether paid or unpaid, between University employees or students and the company and that students may only be engaged by the company (e.g., as employees, interns, or consultants) with the prospective approval of their department chair.
- I understand that the COIC must prospectively approve the additional award of equity in the company to myself or any other University employee or student or members of their immediate families, and/or to the University.
- I understand that I am not covered by Pitt’s insurance policies when performing work for the company, and, specifically, any work I perform in connection with potential investors in the company.