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Organizational Conflict of Interest Policy

It is the policy of Impact Proteomics, LLC to identify, and avoid or manage, actual or perceived Organizational Conflicts of Interest related to research activities in accordance with federal and other sponsor requirements.

Scope

This policy applies to all managers and staff at Impact Proteomics.

Background

Impact Proteomics (IMPACT) receives funding for research activities from a number of U.S. governmental agencies. As a condition of certain funding, IMPACT must adhere to requirements set forth in the Federal Acquisition Regulations (FAR), Defense Federal Acquisition Regulations, and/or contracts. Clauses relating to Organizational Conflicts of Interest (OCI) are common. The purpose of these requirements is to ensure that the research serves the national and public interest and is guided solely by the objective results of the scientific method. Furthermore, recipients of federal funds sometimes receive information considered to be proprietary, confidential and sensitive which must be protected from inappropriate disclosure.

An OCI is a circumstance in which IMPACT (or a representative thereof) may have unequal access to government information or the existence of a conflicting role(s) that might bias IMPACT’s judgment in the proposal for, or conduct of, research. The existence of an OCI may mean that IMPACT is unable or potentially unable to render impartial assistance or advice to the Government, IMPACT’s objectivity in performing the research is or might be impaired, or IMPACT may have an unfair competitive advantage.

An OCI can occur when a member of IMPACT’s community is providing the Government with engineering, scientific, and technical direction, or advisory, analysis, assistance, and evaluation services, or preparing specifications and work statements, or acting in a capacity that gives them access to proprietary data. For purposes of this policy, OCIs occur only in relationship to government-sponsored research activities.

Types of OCI

  • Unequal access to information: an unfair competitive advantage resulting from obtaining information not generally available to others seeking federal
  • Impaired objectivity: assessing performance or evaluating products of someone within your own organization or a direct competitor seeking federal
  • Biased ground rules: having provided engineering or technical assistance or written the work requirements for a funding opportunity where someone within your own organization is an

Identification, Disclosure and Management

The objectives of an OCI program are to identify actual or perceived conflicts and if appropriate disclose them to the sponsor and mitigate or manage the conflict. The goal of this is to prevent or manage circumstances where IMPACT may have biased judgement or an unfair competitive advantage.

Members of IMPACT’s research community are required to disclose their activities that may give rise to an OCI. These activities (on behalf of the U.S. government) include but are not limited to:

  • Contracts to provide scientific, engineering and technical direction;
  • Serving as an advisor and providing analysis, assistance or evaluation services;
  • Preparing specifications and work statements for funding opportunities;
  • Having access to proprietary, confidential or sensitive

Such activities may have been undertaken as an employee of IMPACT or independently as a consultant or volunteer. Disclosure of such activities occurs as part of IMPACT’s annual Conflict of Interest disclosure and certification process. This process is managed by IMPACT’s management team.

In the event a potential OCI is identified and related to proposed or ongoing research at IMPACT, the management team will work with the impacted IMPACT personnel to neutralize or mitigate the OCI.

Management of the OCI may include recusal from certain activities, maintaining confidentiality of data or review of work by an independent third party.