Conflict of Interest Policy

Project Specific Financial Conflict of Interest Policy (fCol)

Any determination by the campus Operations Manager or designee shall be forwarded to the president of the campus. The campus shall be the office of record for all final determinations. The campus Operations Manager shall assure that Research Foundation policies and procedures for maintaining such determinations are in place. Appeal An officer or employee who disagrees with the determination of the campus Operations Manager may appeal to the president of the College, or the president's designee, for reconsideration of such determination. The determination of the president shall be final and binding. Violation In addition to any penalty contained in any provision of law or federal policy, officers or employees who knowingly and intentionally violate any of these provisions may be suspended from or terminated from employment with the Research Foundation if employed by the Research Foundation, or if not employed by the Research Foundation their relationship with the Research Foundation may otherwise be terminated. References RF Conflict of Interest Policy: https ://portal .rf su ny. org/portal /page/po rta l/Tbe%2OResearch%2OFoundation%20of>/o20SUN YI home/commercialization/comm policies guidance/conflict of interest policy Procedure for Investigating Conflict of Interest https ://portal .rfsuny.org/portallpage/portal/Accounts Payabl e/Compliance%20and%20Manitori ng/General/ap investigating-conflict-interest pro .htm

Sponsored Program Authorization contains the Disclosure of Conflict of Interest Form: http ://www.sunyopt.edu/pdfs/academics/Sponsored Program .pdf

Approval RF Operations Manager---+~------~----<..__

Date i{L..." / L '2.­

______

David A. Bowers

Vice President for Academic Affairs --~~~~~~~1bJ\.i.---:~~-==-...,....- Date '-{ ( ~ 1 / / '-­ David Troilo

revision 1.0 I 0412612012

Conflict of Interest Policy

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