At times, research collaborations, or other funded projects at the University, may involve persons related by blood, marriage, membership in the same household, including domestic partners, or persons with whom a faculty member or staff member has an intimate relationship. Such collaborations may create, or give the perception of creating, a conflict of interest. University policy requires such conflicts of interest to be disclosed, reviewed, approved and, if necessary, managed by the Office of the Dean of the Faculty (ODoF) with the assistance of other applicable departments, as needed. This policy is necessary to provide assurance that personnel engaged in research can work in an environment free of bias where they can be objectively supervised and evaluated. Factors such as the nature of the relationship, level of decision-making authority, and, where applicable, the appropriate notices to funding agencies and subrecipients, will be considered. Mitigation measures may include, among other things, assigned independent intermediaries or approvers.

This guidance applies to internally funded and externally funded/sponsored research opportunities or projects that fall within the Nepotism policy because they present a situation where one individual has the ability to initiate, or participate in, directly or indirectly, specific types of decisions outlined in Rules and Procedures of the Faculty involving a direct benefit to another with whom they have a Familial Relationship or Intimate Relationship (as those terms are defined below). 

DEFINITIONS

• “Familial Relationship” means those interpersonal relationships that include, but may not be limited to, persons related by blood or marriage, partnership or adoption, or membership in the same household, including domestic partners. This definition includes a child, grandchild, sibling, spouse, domestic partner, civil union partner, parent, or grandparent of an employee or of the extended family, e.g., in laws, or any other individual related by blood to the employee or whose close personal association with the employee is the equivalent of a family relationship. Close personal associations or friendships are characterized by interactions based on strong or deeper bonds of mutual affection, interconnection, and obligation that reasonable persons would agree to have the potential to create a real or perceived conflict of interest generally comparable to those associated with relatives or household members. It does not include more casual, superficial, transactional, intellectual, or collegial connections, friends, and friendly interactions that are common or natural in the workplace.
• “Intimate Relationship” means those interpersonal relationships that may include persons with whom a faculty or staff member has an intimate, romantic, and/or sexual, relationship. 

REQUIRED PROCEDURES

DISCLOSURE

Individuals who seek to pursue internally funded or externally funded/sponsored research opportunities or projects where one individual has the ability to initiate, or participate in, directly or indirectly, specific types of decisions involving a direct benefit to another with whom they have a Familial Relationship or Intimate Relationship (hereinafter “Collaborators”) must disclose details regarding the relationship and opportunity to Kristine Ryan, assistant dean of compliance, in ODoF. Disclosure is required for Collaborators who are in a Familial Relationship or Intimate Relationship at the time of the required disclosure, and/or at any time during the pendency of research/project/collaboration. 

This disclosure must be made prior to pursuing the research or project opportunity or seeking funding, whichever is sooner. The disclosure must include:

1. Collaborators’ names, titles/ranks, departments, identification of employer (if not Princeton University)
2. Description of the nature of the Familial Relationship or Intimate Relationship
3. Description of the nature of the research or project, including:
   • Title
   • Funding source
   • Role of each Collaborator
   • Research or Project objectives
   • A brief statement explaining why it is necessary or particularly advantageous to the project that approval be granted for the Collaborators. For example, the Collaborators may explain the specialized expertise, skillset, or technique that each Collaborator brings to the research project that explains and supports the collaboration despite the conflict or appearance of a conflict. This statement could also include descriptions of previous research history and any joint publication history. Where applicable, the statement may identify funding the Collaborators previously received from federal agencies, the University, or other sources with knowledge of the Familial Relationship or Intimate Relationship.
   • The Collaborators’ proposed strategies for mitigating any conflict of interest or appearance of a conflict of interest, including assigned or third-party approvers of costs and expenses or disclosure to relevant funding agencies, for example.

REVIEW

ODoF will review the disclosure and confer with other departments as necessary, including, but not limited to, Research Integrity & Assurance, Office of Research & Project Administration, and Chair of applicable departments. 

APPROVAL

Collaborators must receive written approval from ODoF prior to pursuing the internally funded or externally funded/sponsored research opportunities or projects. Approval will be granted on a per project basis or as otherwise provided by ODoF. Approval for one project does not guarantee approval for other projects. The written approval may require the Collaborators to implement mitigation strategies, including but not limited to:

1. Updated disclosures on the Collaborators’ annual COI reporting forms
2. Additional internal disclosures to Department Chairs, funding sources, and other relevant entities or departments
3. Additional external disclosures to the funding agencies, subaward recipient institutions or prime institutions 
4. Mitigation measures, including a management plan to be administered by ODoF in partnership with Office of the Dean for Research. By way of example, such management plans may require:
5. A third party to sign-off on invoices or expenses involving family members or to approve the spending of funds at the subcontract level,
6. An alternative reporting structure to eliminate any real or perceived conflict relating to salary, working conditions, evaluation, promotion, or discipline,
7. Any other requirements of the funding agency or source, Princeton University, or other relevant parties. 

Updated July 5, 2024