LSC Policy Compliance Statement

General terms of the Policy Compliance Statement (PCS) include:

 

Condition

Details

1. Supervisor Approval and MyDisclosures
  • You must obtain approval from your Primary Supervisor to participate in the outside activity. For faculty, this is your department chair, division chief or equivalent faculty supervisor who completes your annual performance evaluation. For staff, this is the person who completes your annual performance evaluation.
  • You must update your Annual Disclosure Certification in MyDisclosures when you anticipate changes to your relationship with the company. This includes, but is not limited to, when you intend to initiate new roles or responsibilities for the company or proposing to participate in research that is related to the company.
  • Changes to your relationship with the company may require approval from the Conflict of Interest Committee or the Institutional Conflict of Interest Committee.
2. Disclosure to Funding and Regulatory Agencies
  • You must disclose your relationship with the company in applications or proposals to fund research when required by the funding agency or other funding source. 
  • You must disclose your relationship with the company to regulatory agencies (e.g., the Food and Drug Administration) when required.
3. Business Decisions and Negotiations
  • You are not permitted to participate directly in negotiations related to business decisions involving the University and the company. 
  • You may not sign agreements between the University and the company on behalf of either party. 
  • You are permitted to advise regarding business decisions involving the University and the company. An employee of the company or other third-party designee, such as a company attorney, who is not subject to University policies must instead participate directly in such negotiations and sign on behalf of the company.
  • If you will be involved in any business decisions related to interactions between the University and the company, you must disclose your relationship with the company to all relevant individuals at the start of any such communications.  This includes but is not limited to communications about purchases, licenses or options, research support, and gifts. 
4. University Research
  • You must contact the Conflict of Interest Division (coi@pitt.edu) prior to conducting University research that relates to the company. 
  • For related animal and human research, you must ensure my financial interests are disclosed in all related protocols.
  • The Conflict of Interest Division and, when necessary, the Conflict of Interest Committee or Institutional Conflict of Interest Committee, will determine when there is a conflict of interest that requires a conflict management plan.
5. University Principal Investigator
  • You may serve as the Principal Investigator of University non-human subject research that relates to the company, subject to conflict of interest review and management.
  • You are prohibited from serving as the Principal Investigator of University human subject research that relates to the company. This includes a prohibition against serving as the Principal Investigator of a human subject research protocol and any sponsored research agreement or subaward from the company to the University that supports human subject research. You may serve as a co-investigator in such research, subject to conflict of interest review and management.
6. Company Research
  • You must notify the Conflict of Interest Division (coi@pitt.edu) if you plan to serve as a Principal Investigator or co-investigator on a company grant proposal, including small business proposals.
7. Time Commitment
  • Faculty members may be permitted to spend a certain amount of their University time on outside activities.  All faculty members must ensure the time they spend on outside activities, including any work for the company, adheres to University policies. Additional information is available here
  • Staff members may not spend any University time on their outside activities.  Staff members must ensure the time they spend on outside activities, including any work for the company, occurs only during their personal time.
8. Confidential Information
  • You must not disclose any confidential or non-public University information or data to the company or use such data when acting on behalf of the company.
9. University Funds and Resources
  • You may not use University funds or resources when acting on behalf of or to otherwise benefit the company.  “Resources” include but are not limited to University facilities, personnel, students, and equipment.  
  • Any proposed use of University resources by the company must be authorized by an institutional agreement between the University and the company, which will be subject to conflict of interest review and management. This includes but is not limited to the use of University facilities (e.g., space, equipment).
10. Research Records
  • You must not share University research records, including data or outputs, with the company absent an institutional agreement between the University and the company authorizing such record sharing. A proposal to initiate such an agreement will be subject to conflict of interest review and management. An exception may be made for research records that are already published or are otherwise publicly accessible.
11. University Logos, Trademarks or Service Marks
  • You must not use University logos, trademarks or service marks when acting on behalf of the company.
  • You must not authorize the company to use University logos, trademarks or service marks.
12. Academic Freedom
  • You must not make any agreement with the company that restricts your ability to conduct or publish University research.
13. Insurance
  • Your relationship with the company is one you undertake in your personal capacity and not as a University employee. 
  • You will not be covered by University insurance policies when performing work for the company, including in connection with potential investors in the company.
14. Students
  • You may not invite University students to participate in company activities outside of the University. A company employee who is not affiliated with the University may invite University students to participate in company activities outside of the University. 
  • Students may engage in company activities outside of the University, provided the student’s non-conflicted supervisor prospectively approves. If you supervise such students at the University, you must contact the Conflict of Interest Division (coi@pitt.edu) to request that an independent liaison be appointed at the University to serve as a non-conflicted source of support should the students have conflict of interest-related concerns.
  • If a student proposes thesis research that relates to the company, you may serve as a member of their dissertation, thesis or other committee, provided 1) you prospectively disclose your financial interests in the company to the student and to all other committee members and 2) the majority of committee members have no financial interests in or relationships with the company.
15. Licensed Start-up Company Requirements
  • The Conflict of Interest Committee must prospectively review and approve proposed transactions between the University and all University Licensed Start-up Companies This includes but is not limited to Company proposals to:
    • Execute or amend an option or license agreement with the University
    • Sponsor or provide in-kind support for University research
    • Initiate a subaward to the University
    • Request a data sharing or data licensing agreement with the University
    • Donate a gift to the University
  • The Conflict of Interest Committee must prospectively review and approve proposed interactions between University Members and the Licensed Start-up Company.  This includes initiating or revising a consulting, advising, officer or other relationship between the company and a University Member.