Revision 1.0

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Policy

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Conflicts of interest can arise at the organizational level. The U.S. government, in particular, has strict rules relating to the award and performance of federal contracts by contractors who have, or appear to have, an Organizational Conflict of Interest (OCI).

 

“Organizational conflict of interest” is a term applied to indicate that, because of its activities, relationships, or contracts, an organization:

1.  May be unable (or potentially unable) to render impartial assistance or advice to the government;

2.  May be unable to perform the contract work in an objective manner; or

3.  Has an unfair competitive advantage because, for example, it has gained access to competitive information or is otherwise able to favor itself.

 

It is IDEAS-TEK’s policy to make pro-active assessments for the presence of any potential organizational conflict of interest - either real or perceived - in doing business with the government.

 

The purpose of this policy is to protect the integrity of IDEAS-TEK and its contracting process. The rules around OCI are not always prescriptive and judgment must be applied. The most important aspect is to identify potential OCI issues as soon as possible in the government procurement process. The earlier identified, the more likely

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Procedures

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Prior to undertaking a government proposal or subcontract, all proposed Investigators shall complete the Conflict Of Interest Disclosure Form (included in the last section below). Here the Investigator will assert whether or not there is a known COI that could arise in getting awarded this contract in regards to the three points listed above in the Policy section. This form will be submitted for review to an appointed COI Committee, which will make a recommendation as to whether or not the Investigator should be approved for inclusion in the proposal.

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Investigator means the principal investigator, the co-principal investigator, and any other person (including staff, subcontractors, or consultants) who is responsible for the design, conduct or reporting of a contract. Any individual responsible for a task that could have a significant effect on the research design, conduct or reporting is considered to be an Investigator, even if the individual does not have the sole or primary responsibility for the task or research.

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Some common examples of potential COI include, but are not limited, to:​​

• Gaining access to non-public information through performance of a federal contract that gives IDEAS-TEK a competitive advantage over others;

• Evaluating or assessing the performance of products/services of others within the same organization or a firm with which IDEAS-TEK is actively contracting with;

• Being involved with preparing or writing specifications or work statements that are used in a funding opportunity;

• Offering or accepting gratuities or special favors from entities with which IDEAS-TEK does or may conduct business with;

• Negotiating or influencing the negotiation of contracts between IDEAS-TEK and any outside entity in which the Investigator has a prior or current consulting, equity or fiduciary relationship.

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Mitigation Plans

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When potential organizational conflicts arise, a carefully crafted mitigation plan can work to remove the presence or appearance of impropriety. Common elements of a mitigation plan could include procedures such as entering into non-disclosure agreements, controlling access to sensitive information, establishing an OCI awareness and compliance program, and establishing firewall plans. There are also ongoing requirements during contract performance that may need to be reported. The OCI review process is a complete lifecycle review beginning with proposal preparation and submission through contract execution and closeout.

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Conflict of Interest Disclosure Form

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This Conflict of Interest (COI) Form should indicate whether the Investigator(s) has an economic interest in, or acts as an officer or a director of, any outside entity whose financial interests would reasonably appear to be affected by the award of a contract or subcontract. The Investigator(s) should also disclose any personal, business or volunteer affiliations that may give rise to a real or apparent conflict of interest. Relevant federally and organizationally established regulations and guidelines in financial conflicts must be abided by. Individuals with a conflict of interest should disclose the nature of the COI and either provide a mitigation plan to avoid the influence of COI or bow out of involvement with the proposal.

 

Principal Investigator: ______________________ Topic/Proposal/RFP#________________________

 

Funding Agency:___________________________ Prime Contractor: __________________________

 

RFP Title: ____________________________________________________________________________

 

Please describe below any relationships, transactions, positions you hold (volunteer or otherwise), or circumstances that you believe could contribute to a conflict of interest for this proposal:

 

___ I have no conflict of interest to report.

 

___ I have the following conflict(s) of interest to report (please attach additional pages if necessary, and appropriate mitigation plan if applicable):_________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

 

I hereby certify that the information set forth above and any accompanying attachments is true and complete to the best of my knowledge.

 

Signature of Investigator:______________________________ Date: ___________________________

 

Executive Committee hereby ___approves / ___ approves with mitigation / ___denies Investigator for inclusion into the above referenced proposal.

 

Signature of CIO Committee Rep.___________________________ Date: ______________________