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Conflict of Interest in Research. NCI Ethics and You. A Primer for New Employees. MISSION. To stimulate and support scientific discovery and its application to achieve a future when all cancers are uncommon and easily treated. GOALS.

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conflict of interest in research
Conflict of Interest in Research

NCI Ethics and You

A Primer for New Employees

mission
MISSION

To stimulate and support scientific discovery and its application to achieve a future when all cancers are uncommon and easily treated

goals
GOALS
  • To acquire new knowledge to help prevent, detect, diagnose, and treat disease and disability
  • To sustain the Nation’s medical research capacity
  • To provide Federal stewardship
goals4
GOALS
  • And do it with the highest possible integrity and responsibility in the conduct of science
the non government to government transition
The Non-Government to Government Transition
  • Retool your basic assumptions…
the non government to government transition6
The Non-Government to Government Transition
  • A Federal job is a public trust
the non government to government transition7
The Non-Government to Government Transition
  • Federal corporate ethics are laws and regulations
    • Executive Orders
    • Federal Laws
    • Federal Regulations
conflict of interest in research8
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
conflicting financial interests
Conflicting Financial Interests

Business thought says,

“Put your money where your mouth is—invest in what you believe in!”

Federal thought says,

“If the government pays you to work on it, keep your personal finances out of it.”

conflicting financial interests10
Conflicting Financial Interests
  • Federal criminal law says that you cannot take official action in your job on matters that will have an effect on your personal financial interests
conflicting financial interests11
Conflicting Financial Interests
  • They include:
  • Stocks, stock options, bonds
  • Mutual funds and sector funds
  • Salary, fees, honoraria, or other income
  • Invention rights and royalties
  • Employment interests--professional position or title
conflicting financial interests12
Conflicting Financial Interests

Personal financial interests are those of:

  • Yourself
  • Spouse
  • Minor children or legal dependents
  • Organization in which you are a partner, officer, trustee, board member, employee
  • Organization with whom you are seeking employment
conflicting financial interests13
Conflicting Financial Interests
  • Federal employees, researchers, medical personnel, administrators, contracting personnel, grants personnel, procurement personnel, and others holding positions of trust…
conflicting financial interests14
Conflicting Financial Interests
  • Should not own >$5,000 in stock in the associated company
  • Should not have a spouse…working for the company
  • Should not have an outside activity with the company
  • Should not be negotiating for employment with the company
  • Should not accept sponsored travel/gifts from the company
conflicting financial interests15
Conflicting Financial Interests
  • What should you do if you think you have a conflict of interest?
conflicting financial interests16
Conflicting Financial Interests
  • DISQUALIFY
    • Stop, do not pass go, do not collect $200
conflicting financial interests17
Conflicting Financial Interests
  • DISCLOSE
    • Contact your Ethics Official
conflicting financial interests18
Conflicting Financial Interests
  • RESOLVE
    • Work out a Solution
contacting nci ethics officials
Contacting NCI Ethics Officials
conflict of interest in research20
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
impartiality in performing official duties
Impartiality in Performing Official Duties

A Question of Fairness

You should not act on a matter if a reasonable person who knew the circumstances of the situation

  • Could legitimately question your fairness or
  • Imply bias or favoritism
impartiality in performing official duties22
Impartiality in Performing Official Duties
  • What may imply bias or favoritism?
  • Acting in an official duty matter
    • Involving a relative who is not your spouse, minor child or legal dependent
    • Involving an organization in which your spouse, minor child, or legal dependent is seeking employment
    • Involving someone who paid you a salary, fee, honorarium,… within the last 12 months
    • Involving an individual with whom you have a close personal or professional relationship
impartiality in performing official duties23
Impartiality in Performing Official Duties
  • What is the test for impartiality?
  • Would you be comfortable reading about it in the Washington Post?
  • Would you like your mom to read about it in the newspaper?
impartiality in performing official duties24
Impartiality in Performing Official Duties
  • What do you do if you think you have a problem?
  • Contact an NCI Ethics Official
    • [email protected]
    • Bethesda Office 301-496-1148
    • Executive Blvd. Office 301-9950
    • Frederick Office 301-846-5286
conflict of interest in research25
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
misuse of position
Misuse of Position

You cannot use your position with the Government for your own personal gain or for the benefit of others---this includes:

  • Family
  • Friends
  • Neighbors
  • Charitable causes
  • Others
misuse of position27
Misuse of Position
  • Also, you may not use Government resources including:
  • Property - phones, computers, facilities
  • Time – yours or others
  • Non-public information
conflict of interest in research28
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
representation
Representation

A Federal law prohibits employees from representing the interests of any individual or organization before any agency of the Federal Government with the intent to influence.

EXCEPT

  • Self
  • Spouse, minor children, and legal dependents
  • Parents
representation30
Representation

Examples:

  • Testifying in a Federal Court other than for the US Government
  • Appearing before Congress on behalf of an outside organization
    • Lobbying
    • Political Activities
  • Advocating for award of grant or contract
  • Representing a friend or neighbor before a branch of the US Government
    • Social Security
    • Peer Review
conflict of interest in research31
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
gifts
Gifts

You may not ask for or accept a gift from persons or organizations who:

  • Do business with or seek to do business with your agency
  • Seek official action by your agency
  • Are regulated by your agency
  • Have interests that may be significantly affected by you when you are doing your job
  • Are giving you a gift because of your official positions
  • Gifts can be viewed as bribes under the law
gifts33
Gifts

What is a Gift?

  • Gratuity
  • Favor
  • Discount
  • Entertainment
  • Hospitality
  • Loan or Forbearance
  • Other item having monetary value
gifts34
Gifts

What is not a Gift?

  • Modest food and refreshments at a meeting
  • Loans generally available from commercial lenders
  • Benefits, rates, discounts generally available to the public or all Government employees
  • Plaques, certificates or trophies
  • Rewards or prizes given as part of public events
  • Pensions or other benefits from participation in an employee benefit plan
  • Anything bought or secured by the Government
  • A Gift accepted by the Government under law
gifts35
Gifts

What are exceptions to the gift provisions?

  • Gifts valued at $20 or less and no more than $50/source/yearNO CASH or SECURITIES!
  • Waiver of registration for a meeting at which you are speaking
  • Authorizedattendance at a widely attended event of interest to your agency
conflict of interest in research36
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
activities with outside organizations
Activities with Outside Organizations

What you can do

Depends on what you do for the

Government

~Need prior clearance~

activities with outside organizations38
Activities with Outside Organizations

Generally

  • Activities involving professional competence with organizations outside the Department of Health and Human Services
activities with outside organizations39
Activities with Outside Organizations
  • Teaching and Speaking
  • Writing and Editing
  • Consulting/Advising
  • Legal Consulting/Advice
  • Outside Clinical Practice
  • Legal Advice
  • Serving on Boards and Committees
activities with outside organizations40
Activities with Outside Organizations

Official - You represent the NCI

  • Related to professional and official competence
  • Use Government title and affiliation
  • Use Government resources
  • Use Government time
  • Use Government travel –sometimes reimburseable
  • May talk about current projects***
  • May serve on boards and committees***
  • May provide advice, but generally not consult***

***with limitations

activities with outside organizations41
Activities with Outside Organizations

Personal - You represent yourself

  • Related to professional competence
  • May be compensated or uncompensated
  • May not use your Government title and affiliation
  • May not use Government resources if compensated
  • May not use Government time if compensated
  • May not use Government travel – may be reimbursed in certain circumstances
  • May not use non-public information or discuss your current projects within the last 12 months
activities with outside organizations42
Activities with Outside Organizations
  • What if you can’t decide whether it is official business or personal activity?
  • Contact an NCI Ethics Official
activities with outside organizations43
Activities with Outside Organizations
  • How do you obtain clearance?
activities with outside organizations44
Activities with Outside Organizations

BEFORE YOU ACCEPT…..

  • Talk to your SUPERVISOR
  • Contact the Ethics Office

[email protected]

activities with outside organizations45
Activities with Outside Organizations

Before You Begin….

  • Clear through your ARC
  • Obtain Approval by submitting paperwork to the NCI ETHICS OFFICE Office nearest you.
      • Bethesda Office 31/4A48
      • Frederick Office 372/12
      • Executive Blvd 6116/Suite 600
      • Forms may be found athttp://ethics.od.nih.gov/forms.htm
conflict of interest in research46
Conflict of Interest in Research
  • Conflicting Financial Interests
  • Impartiality in Performing Official Duties
  • Misuse of Position
  • Representation
  • Gifts
  • Activities with Outside Organizations
  • Seeking Other Employment
seeking other employment
Seeking Other Employment
  • Federal criminal law says that you cannot take official action in your job on matters that will have an effect on your personal financial interests
  • The relationship developed in seeking employment is a financial interest
seeking other employment48
Seeking Other Employment

What do you do if you wish to seek outside employment?

  • DISQUALIFY – if needed
  • DISCLOSE – as necessary
  • RESOLVE – if required
conflict of interest commandments
Conflict of Interest Commandments
  • Avoid Conflicting Financial Interests
  • Maintain Impartiality in Performing Official Duties
  • Don’t Misuse Government Position
  • Don’t Represent Outside Organizations to the Federal Government
  • Be Careful of Non-Feds Bearing Gifts
  • Get Prior Authorization for Activities with Outside Organizations
  • Avoid Conflict of Interest in Seeking Outside Employment
media inquiries
Media Inquiries

Contact the Press Office when:

  • Your study is accepted for publication
  • A journalist calls you for an interview
  • You need background material for reporters
  • A development in your field is likely to generate media attention

General Contact Information: 301-496-6641. email: [email protected]

congressional inquiries
Congressional Inquiries
  • Call the Office of Congressional and Legislative Affairs:

301-496-5217

legal inquiries
Legal Inquiries
  • Contact the Office of General Counsel

301-496-4108

conflict of interest commandments53
Conflict of Interest Commandments

If you can’t figure it out…

conflict of interest commandments54
Conflict of Interest Commandments

Contact an NCI Ethics Official

  • [email protected]
  • Bethesda Office 301-496-1148
  • Frederick Office 301-846-5286
  • Executive Blvd. Office 301-496-9950

For further information see

  • http://ethics.od.nih.gov/
  • http://camp.nci.nih.gov/public/ethics/index.html
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