Conflict of Interest

As part of Syracuse University’s ongoing commitment to conduct all of its business activities in a fair and ethical manner, all non-bargaining unit employees are required annually to file a brief Conflict of Interest (COI) disclosure questionnaire. The purpose of these disclosures is to identify potential situations where an employee or close relative may be in a position to inappropriately influence or benefit from a financial transaction or employment relationship. Once identified, every effort is made to mitigate the potential conflict in order to avoid the possibility or appearance of impropriety.

The annual COI disclosure process is administered through the Office of Compliance and is typically launched in April when employees are instructed to login to the MySlice portal and complete their personalized online COI disclosure questionnaire. Employees with questions or concerns related to COI, or who need to update their current COI disclosure questionnaire for any reason, should contact the COI administrator at


Conflict of Interest Administrator
Office of Compliance
Syracuse University
621 Skytop Road, Suite 100-12
Syracuse, New York 13244-5290

Financial Conflict of Interest

The guiding principle behind this process is intended to promote objectivity in research by defining a set of standards that provide a reasonable expectation that the design, conduct, and reporting of research will be free from bias resulting from investigator (any individual responsible for the design, conduct, or reporting of research) financial conflicts of interest.

What is a Financial Conflict of Interest?

A Financial Conflict of Interest (FCOI) arises whenever the design, conduct, and reporting of research is compromised by, or could reasonably be perceived as being compromised by, a person’s financial interests. A financial interest is anything of monetary value, whether or not the value is readily ascertainable, that reasonably appears to be related to a person’s institutional responsibilities including their research. Please see the section on Significant Financial Interests for more information. A FCOI is based on the situation itself and in no way reflects on or speaks to the character of the individual in any way. See Syracuse University’s Policy on Conflict of Interest for additional information.

Who must disclose?

Any individual responsible for the design, conduct, or reporting of research, regardless of title or position, must complete a FCOI disclosure at least annually. Individuals meeting this definition may include faculty, staff, post- doctoral fellows, graduate students, and/or others who assume independent responsibility for the design, conduct, or reporting of research.

When is disclosure required?

Significant financial conflicts of interest must be disclosed as follows:

  • Prior to engaging in research
  • Within 30 days of discovery or acquisition of a new Significant Financial Interest
    • Ex. Start-up company is formed OR cumulative payments for past 12 months now exceed significant financial interest threshold of $5,000
  • Annually during the Syracuse University annual disclosure process (even if acknowledging no change to previous disclosure)

What do I need to disclose?

  • Relationships and activities that are related to your Syracuse University Sponsored Research responsibilities
  • Any financial interests in an organization that is related to your sponsored research at Syracuse University (consulting, advising, speaking)
    • This applies if the organization is related to your field or could benefit from your professional expertise
  • Ownership of, or investment in, a start-up company related to your field even if it is not currently worth anything
    • You must disclose within 30 days of the investment, the filing paperwork as a founder, or the acquisition of ownership interest (options, shares, etc.)
  • Current academic appointments or salary outside of Syracuse University (does not apply to salary from previous academic appointments before arriving at SU)
  • Use of Syracuse University resources for outside activities (including staff, software, equipment and/or instruments, lab or research space, or confidential information)

What should I not disclose?

  • Salary, royalties, or other renumeration paid by Syracuse University
  • Salary from a previous academic appointment or institution prior to your start date at Syracuse University
  • Service on an NIH study section, or NSF grant review panel.  Service for federal sponsors is exempt from disclosure
  • Mutual funds or other retirement holdings that you do not actively manage
  • Ownership interests in a commercial entity if Syracuse University is an applicant under the SBIR (or STTR) Phase I program
  • Grants or sponsored research funds that you received while at Syracuse University that went through the Office of Sponsored Programs
  • Volunteer activities in your community likely do not need to be disclosed unless you use Syracuse University resources to perform the activities
    • Ex. Routine use of a Syracuse University copier machine or printer to create flyers or use of Syracuse University software or resources for those activities
  • Sponsored or reimbursed travel paid by a federal, state, or local government agency, institution of higher education, academic teaching hospital, or research institute
  • Activities or relationships that are unrelated to your field and/or work at Syracuse University
    • Ex. A family-owned pizzeria (unless you purchase that pizza for department functions or refer other departments at SU to that pizzeria)

Common Examples:

An invited lecture at another academic institution

  • NO disclosure IF it was a one-time lecture or speaking engagement.
  • YES disclosure IF you taught an entire course at another institution and/or received an appointment at the other institution


  • NO disclosure IF the stock is unrelated to your work at Syracuse University
    • Ex. Amazon or Google stock (unless you are teaching a class on developing search algorithms or advertising)
    • Ex. Anything in your retirement accounts or a managed portfolio where you are not responsible for deciding what you invest in
  • YES disclosure IF the stock is in a publicly traded company related to your research or your clinical trial
    • Ex. You own Pfizer stock AND you are conducting research sponsored by Pfizer in your lab or participating as an investigator in Pfizer clinical trials


  • YES disclosure IF you have ownership interest OR a management role in a company, and that company retains a student to provide services (paid or unpaid) and any of the following occurs:
    • The student is currently enrolled in your class (or a close relation’s class)
    • You (or a close relation) supervise the student in an academic capacity
    • You (or a close relation) have the ability to influence the academic progress of the student
    • You (or a close relation) supervise the student as a research assistant or student employee

Disclosure Thresholds

In accordance with Syracuse University Policy, Significant Financial Interests (SFIs) are defined as follows:

Compensation and/or other payments for service

  • Threshold: Exceeding $5,000 aggregated over a 12-month period must be reported
  • Exclusions: Compensation received that is cumulatively less than $5,000, OR compensation received for lectures, seminars, teaching engagements, or service on an advisory committee or review panel for federal, state, or local government agencies, OR compensation received from Syracuse University

Equity interests/Stocks in publically-traded entity

  • Threshold: Exceeding $5,000 or 5% ownership in a single entity
  • Exclusions: Interests in publicly-traded entities valued at less than $5,000, as well as interests in any entity through personal retirement accounts and mutual funds

Equity interests/Stocks in non-publically-traded entity

  • Threshold: $0, Any must be reported
  • Exclusions: Interests/ stocks through personal retirement accounts and mutual funds that are not actively managed by the investigator

Intellectual Property Rights (patents, copyrights, royalties)

  • Threshold: Exceeding $5,000 must be reported
  • Exclusions: Royalties received from Syracuse University funds, unlicensed IP that does not generate income

Management Roles

  • Threshold: Director, officer, or other position (that has significant decision-making authority) in a research sponsor (or 3rd party receiving the funding) or company whose interests are related to your research

Sponsored or Reimbursed Travel

  • Threshold: Exceeding $5,000 must be reported
  • Exclusions: Travel administered through Syracuse University funds OR travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, or a research institute that is affiliated with an institution of higher education

Syracuse University’s Training Plan for FCOI

Syracuse University requires mandatory training for all “Investigators” meaning “the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of externally funded projects, or proposed for such funding.”  Training is required prior to engaging in research related to any externally funded project and at least every four years, and immediately when any of following conditions apply: 1) The institution revises its financial conflicts of interest policies or procedures in any manner that affects the requirements of the investigators; 2) a researcher is new to the institution; or 3) when a researcher is found to be out of compliance with the regulations or with the institution’s financial conflicts of interest policy or management plan.

What is the process?

Both the COI questionnaire (required by SU Policy for all SU full-time faculty and staff, and most part-time staff) and the FCOI questionnaire (required by federal regulation and enacted in SU Policy) is accessible through the MySlice portal. The annual disclosure process begins in April.

Where can I find more information?