The University recognizes that its Faculty and Staff participate in outside activities (e.g., consulting, serving on boards of companies or advisory panels, being involved with start-up companies) that benefit the participant and the University, its students, patients, and the community at large.  Outside activities do not automatically present a concern but they could give rise to actual or perceived conflicts of commitment or interest.  The University and its Faculty and Staff have a shared interest in assuring the institutional integrity of the University as well as the personal and professional integrity of its Faculty and Staff.

The University's COI Policy (formally Policies on Conflicts of Commitment and Interest) is intended to promote conducting the University's academic, administrative, and research activities in a fair and objective manner in accordance with the law, ethical standards addressing conflicts of interest and commitment, and the best interests of the University.

The Conflict of Interest Committee (COIC) is the governing body which has the authority to make decisions regarding the classification, management and reporting of conflicts of interest or commitment. The COIC is comprised of Faculty and Staff with knowledge in human subjects research, ethics, legal issues and financial investments. COIC members are nominated by the Committee on Research and appointed by the President of the University. The current chair of the COIC is Onnig H. Dombalagian, George Denègre Professor of Law at Tulane Law School.

A Conflict of Commitment (COC) occurs when the Primary Commitment to University activities and responsibilities is compromised by one or more Leadership Roles or Secondary Commitments. For example, a Conflict of Commitment would occur if a Faculty member exceeded permitted time limits on outside consulting, or if, as a result of a Leadership Role in an outside organization, entity or project, an individual’s primary professional loyalty was not to the University.

A Conflict of Interest (COI) arises whenever Faculty, Staff, or an affiliated Investigator’s Professional Interests, such as professional obligations or judgment owed to the University and its constituencies, are compromised by, or could reasonably be perceived as being compromised by, his or her Leadership Roles or Financial Interests. In the case of PHS-Funded Research, a PHS Financial Conflict of Interest arises when the Financial Interests of an Investigator could directly and significantly affect the design, conduct, or reporting of PHS-Funded Research. A Conflict of Interest can also occur when the academic work or research activities of a Faculty member could affect a Financial Interest of the University or of a Faculty or Staff member.

All Faculty and Staff and affiliated Investigators are required to submit a Conflict of Commitment and Interest Disclosure of Information Form within 60 days of hire and thereafter annually and no later than 30 days after the acquisition or discovery of a new Financial Interest, Leadership Role or Secondary Commitment or the material modification of such Interest, Role or Commitment.

General inquiries about Conflicts of Commitment or Interest can be directed to coi@tulane.edu or (504) 247-1286.

You may report concerns you have about Conflicts of Commitment or Interest to the Confidential Compliance Hotline: 1-855-5GOWAVE (1-855-546-9283). You can also submit a concern electronically at www.mycompliancereport.com/report?cid=TUL.