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Conflict of Interest Policy for DOE-Funded Research 

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1. Purpose 

This Conflict of Interest (COI) policy establishes guidelines for identifying, disclosing, and managing potential conflicts of interest to ensure that all DOE-funded research is conducted without bias and that any significant financial interests (SFI) are appropriately managed. This policy applies to all investigators involved in DOE-supported projects. 

2. Definitions 

  • Investigator: Any principal investigator, co-investigator, or other personnel responsible for the design, conduct, or reporting of DOE-funded research. 

  • Significant Financial Interest (SFI): Includes financial interests that may directly and significantly affect DOE research outcomes, as outlined in the DOE COI policy. 

  • Financial Conflict of Interest (FCOI): Any SFI that could directly and significantly impact the DOE project’s purpose, design, or reporting. 

3. Disclosure Requirements 

All investigators must disclose SFIs: 

  • Prior to submitting a DOE-funded proposal 

  • Annually during the duration of the DOE-funded research 

  • Within 30 days of discovering or acquiring new SFIs 

4. Certification and Training 

Investigators are required to certify that their disclosures are complete, true, and accurate. Certification and COI training must be completed before any DOE funds are expended on the project. 

5. Conflict Management 

Upon identification of an FCOI, the institution will determine if it is manageable. An FCOI management plan will be implemented, specifying restrictions or conditions to mitigate potential bias. 

6. Reporting Requirements 

Institutions must report FCOIs to the DOE prior to the expenditure of any funds if they are unmanageable, following specific terms outlined in the award. An annual report must also be submitted for any ongoing FCOIs, with frequency adjustments as specified in DOE’s guidance. 

7. Organizational Conflicts 

Organizational conflicts of interest will be identified and managed in cases where institutional relationships or financial interests might influence the outcomes of DOE-funded research. 

8. Compliance and Retrospective Review 

In cases where FCOI policies are violated, the institution will perform a retrospective review and report findings, including measures to mitigate any identified bias. 

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