What to Disclose
Applicable to all faculty:
Your responsibility as a faculty member is to report any paid or unpaid domestic or foreign Outside Activities in which you were engaged during the reporting period June 1 of last year through May 31 of the current year. You also have an obligation to provide limited information related to your immediate family members activities and interests.
Include (a) business activities such as Consulting and employment with a public or private foreign or domestic entity, and executive, managerial, or fiduciary responsibilities for a foreign or domestic public or private entity; and (b) professional or academic activities, such as public service or pro bono work, performed outside of the faculty member's appointment, or association to NYU.
Unless required by your school, do not include scholarly and professional activities performed in connection with your appointment to NYU, such as lectures or seminars sponsored by U.S. governmental or non-profit entities, service on advisory committees or review panels for U.S. government or non-profit entities, including professional associations, and services on the editorial board of a journal in the field of your appointment, to the extent:
1. they are uncompensated; or
2. if compensated, you received remuneration in the form of honoraria from a U.S. federal, state, or local government agency, a U.S. based non-profit institution of higher education or academic teaching hospital or a medical center, or a research institute affiliated with a domestic institution of higher education.
Remuneration from all domestic and foreign sources resulting from any Outside Activities that you engaged in or expect to engage in during the reporting period must be disclosed. Remuneration includes salary and any payment for services not otherwise identified as salary (e.g., consulting fees, honoraria, paid editorial or authorship activities). Investigators must disclose all foreign financial interests (which includes income from seminars, lectures, or teaching engagements, income from service on advisory committees or review panels, and reimbursed or sponsored travel) received from any foreign entity, including foreign institutions of higher education or foreign government (which includes local, provincial, or equivalent governments of another country) when such income meets the threshold for disclosure (e.g., income in excess of $5,000). Payment by certain domestic institutions for scholarly and professional activities performed in connection with a faculty member’s appointment to NYU, such as lectures or seminars, editorial or authorship activities, service on advisory committees or review panels (including professional associations), are excluded from the definition. These excluded domestic institutions include: U.S. federal, state, or local government agencies; U.S. based non-profit institutions of higher education; academic teaching hospitals, medical centers, or research institutes that are based in the United States.
Ownership Interests held by you and/or your immediate family members during the reporting period must be disclosed (such as stock, stock options, warrants, partnership and LLP interests) in an entity or organization (including, but not limited to, corporations, limited liability companies, and sole proprietorships) described below:
- Ownership Interests Other than Publicly Traded Stock or Mutual Funds: A direct or indirect Ownership Interest where the organization or entity: does or seeks to do business with NYU; or competes or seeks to compete with NYU.
- Ownership Interests in Publicly Traded Stock or Mutual Funds: A direct or indirect Ownership Interest in (a) publicly traded stock where the collective interest exceeded or will exceed either $5,000 or a 5% interest in any class of the company’s stock or shares, or (b) mutual funds where you or your Immediate Family Members either (1) control the fund, or (2) hold an interest that exceeds $5,000 collectively and is at least a 15% direct or indirect interest in the fund, IF:
- The company competes or seeks to compete with NYU (e.g., a for-profit company in the online education space or a biomedical company seeking to develop a drug being developed at NYU); or
You or your Immediate Family Members have or may have involvement in the decision of NYU to do business with the company (e.g., involvement in a decision by NYU to use Verizon as its telephone service provider).
Ownership Interests for PHS Research and Sponsored Programs: Investigators interested in participating in Public Health Service supported grants or cooperative agreements will need to disclose ownership interests that exceed $5,000 or have ownership interest in the entity at any level.
Royalty Income exceeding $1,000 from a public or private entity that does or seeks to do business with NYU or competes or seeks to compete with NYU must be disclosed and is defined as any royalty income, licensing income or other proceeds (e.g., payments linked to product sales or other usage and milestone payments), or the written contractual right to receive future royalties, licensing income or other proceeds, directly or indirectly, under a pending or issued patent, license, copyright or other property right, and includes, for purpose of disclosure, all income received by the person other than that paid by NYU in accordance with NYU’s intellectual property policies, including its Statement of Policy on Patents.
Loans accepted by you or your immediate family members must be disclosed (other than a loan from NYU or a loan made in the ordinary course of business from a banking or other financial institution).
Gifts/Favors accepted by you or your immediate family members must be disclosed if they are more than nominal value (i) from any Public or Private Entity that has or seeks to have a business relationship with NYU, (ii) from a Public or Private Entity that has or seeks other forms of association with NYU or benefits from NYU, or (iii) that might be perceived as placing you or NYU in a prejudicial or embarrassing position or interfering in any way with your ability to carry out your responsibilities at NYU in an impartial and appropriate manner.
Non - Financial Interests
- Time spent by you on outside activities during the reporting period and while receiving compensation from NYU.
- You or Immediate Family Members’ Executive, Managerial, or Fiduciary Responsibilities to a Public or Private Entity. For purposes of reporting for immediate family members, only report immediate family members executive, managerial, or fiduciary responsibilities in a public or private entity that does or seeks to do business with NYU.
- Any other activities or interests that could constitute an actual or potential conflict of interest or a conflict of commitment under the policy (including situations where you may have received NYU approval for the activity or the interest).
Applicable to Investigators:
Investigators conducting research (sponsored and non-sponsored)
The following additional information is required in the disclosure process in order for faculty and other Investigators to meet the requirements of NYU's Addendum on the conduct of research:
Disclosure of research involving human subjects with more than minimal risks
Disclosure of pre-clinical research (ie. research reasonably anticipated to contribute to an FDA application for research involving human subjects within the next twelve months)
Public Health Service (or other sponsors adopting the PHS regulations) or National Science Foundation
Qualifying criteria as well as differences in reporting periods have been incorporated into the system in order for you to comply with NYU's Addendum regarding the disclosure of financial interests that could directly and significantly affect the design, conduct or reporting of PHS or NSF supported projects and to ensure NYU meets the regulatory compliance obligations for the identification, reporting and management of significant financial conflicts of interest in research funded by federal and other sponsoring agencies (including, but not limited to the Public Health Service of the U.S. Department of Health and Human Services and the National Science Foundation).
Reimbursed or Sponsored Travel
The following category of interest must be reported by Investigators **only for and concurrent with the submission of a proposal to a PHS agency and other sponsors adopting the PHS regulations on conflict of interest**:
Reimbursed or Sponsored Travel: any reimbursed or sponsored travel (i.e. that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available) related to institutional responsibilities, when aggregated with other financial interests exceeds $5,000 per entity in the 12 months prior to disclosure must be reported. Travel reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education, an academic teaching hospital, a medical center or a research institute that is affiliated with an institution of higher education need NOT be disclosed.