DIVISION OF RESEARCH
RESEARCH COMPLIANCE
State University of New York at Binghamton
Research Foundation - Conflict of Interest Policy
The following policy applies to all Research Foundation employees acting in a significant decision-making position,
project directors, or any person who has signature authority for a Research Foundation account.
This includes faculty
and staff with SUNY appointments conducting research through the Research Foundation. An annual disclosure form
is required. Individuals have an option to certify that they have no real or apparent conflicts of interest by simply signing
the form. State employees who must comply with the State Public Officers Law can use that disclosure to satisfy Research
Foundation requirements.
Research Foundation's policy requires that:
"No officers or employees of the Research Foundation should have any interest, financial or otherwise, direct or indirect,
or engage in any business or transaction or professional activity or incur any obligation of any nature, that is in
substantial conflict with the proper discharge of their duties in the best interest of the Research Foundation."
Prohibited activities include:
1. No officer or employees of the Research Foundation shall accept other employment which will impair their
independence of judgment in the exercise of their duties and responsibilities.
2. No officers or employees of the Research Foundation shall accept employment or engage in any business or
professional activity which will require them to disclose information confidential to the Research Foundation that they
have gained by reason of their position or authority.
3. No officers or employees of the Research Foundation shall disclose information confidential to the Research
Foundation acquired by them in the course of their duties except as required by law nor use such information to further
their personal interests, unless such information has previously been made public.
4. No officer or employees of the Research Foundation shall use or attempt to use their position to secure undue
privileges or exemptions for themselves or others.
5. No officers or employees of the Research Foundation shall engage in any transaction as a representative or agent of the
Research Foundation with any business entity in which they, their spouse or any dependant, or any business partners have
a direct or indirect financial interest that might conflict with the proper discharge of their duties or responsibilities.
6. No officers or employees of the Research Foundation, or corporation, firm or association of which such person, their
spouse or any dependent, or any business partners is a member, shall sell, contract for or provide goods or services to the
Research Foundation in connection with a program or project administered through the Foundation in a manner that is
inconsistent with the Foundation's established procurement policy.
7. Officers and employees of the Research Foundation shall not by their conduct give reasonable basis for the impression
that any person can improperly influence them or unduly enjoy their favor in performance of their duties, or that they are
affected by kinship, rank, position or influence of any party or person.
8. Officers and employees of the Research Foundation shall abstain from holding personal investments that they have
reason to believe may be directly involved in decisions to be made by them or that will otherwise create conflict between
their duties in the best interest of the Research Foundation and their private interests.
PO Box 6000, Binghamton, NY, 13902-6000. Ph: 607-777-
6136 Revised 05//06