Ch. 1 - Standards for Conduct of Research at Caltech
1.1 Classified Work on Campus
1.2 Conflict of Interest
1.3 Lobbying and Earmarks
1.4 Nepotism
1.5 Principal Investigator Eligibility
1.6 Principal Investigator Responsibilities
1.7 Research Misconduct
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1.1 Classified Work on Campus
Background
Federal agencies use a classification system to protect national security interests and mission critical information from disclosure. Classification ranges from the least restricted to a Top Secret designation and is primarily applied to defense materials and applications. Classification imposes additional responsibilities upon award recipients, including personnel screening, restrictions on the participation of foreign persons, data use restrictions, and prohibitions on the publication of research results. Classified information differs from "proprietary or confidential" information, terms used by businesses and other entities to protect information from competitors, e.g. trade secret information.
The Caltech Way
Caltech policy does not allow the acceptance of grants or contracts supporting the conduct of classified research or other classified projects on campus. Exceptions to this restriction may be considered by the President of Caltech in times of national emergency or critical need upon an urgent request of the government. Exceptions for short-term use of unique facilities or equipment may also be considered by the President upon recommendation of the Division Chair.
Caltech Faculty Handbook Chapter 7
9/20/10
1.2 Conflict of Interest
Background
A conflict of interest in research arises when an investigator has an outside financial interest with the potential to influence the design, conduct, or reporting of a research project. Caltech is committed to ensuring that decisions made on its behalf reflect the highest ethical standards and that its research and instruction remain a rigorous and open inquiry, unencumbered by conflicts of interest, real or perceived, that might affect the sound judgment of the trustees, officers, senior management, faculty, students and staff.
In the mid 1990's, the National Science Foundation (NSF) and the National Institutes of Health (NIH) issued policies addressing increasing concerns for potential and real conflicts of interests involving research projects sponsored by those agencies. These policies refer to the protection of objectivity in research and require institutions receiving NSF or NIH funding to establish a process for the disclosure, review and management of significant financial interests held by individual investigators. All identified conflicts of interest must be managed, reduced or eliminated prior to the expenditure of funds under the award.
The Caltech Way
Caltech's mission is to expand human knowledge and benefit society through research integrated with education. In pursuit of this mission, Caltech strives for the highest level of integrity and public confidence. Caltech is committed to ensuring the highest ethical standards and that its research and instruction remain a rigorous and open inquiry, unencumbered by conflicts of interest, real or perceived. Each member of the Caltech community, therefore, is responsible for identifying and resolving conflicts of interest. Caltech will comply with sponsor requirements for financial disclosure, review and management. Furthermore, Caltech certifies with each proposal to NSF and NIH that any necessary review and management will be completed prior to expenditure of funds.
Requirements for NIH and NSF Grants
Principal Investigators and other individuals who are involved in the design, conduct, or reporting on NSF or NIH projects, are required to disclose significant financial interests to Caltech. At the time of proposal submission, the Investigator certifies that all relevant financial interests have been disclosed. Investigators are also required to disclose any change in the amount or type of personal financial interests during the life of a funded NSF or NIH project.
Caltech Faculty Handbook Chapter 7
Caltech Conflicts of Interest Policy
Managing Conflict of Interest Requirements Under Federal Sponsored Awards
9/20/10
1.3 Lobbying and Earmarks
Background
Federal regulations prohibit the use of federal grant or contract funds for the purpose of lobbying. Because tax and political compliance laws impose restrictions, and even prohibitions, on certain political activities and on the use of resources, buildings and equipment at a non-profit institution such as Caltech, any such activities must be in compliance with these legal requirements. Applicable laws dictate that no person may engage in any political activity in support of or opposition to any candidate for elective public office on behalf of Caltech or use any Caltech resources for such a purpose. Similarly, no person may lobby on behalf of Caltech or use Caltech's name or resources to lobby any federal, state, or local legislative or administrative official or staff member unless specifically authorized to do so by Caltech. Individuals taking personal political positions must clearly indicate that they are acting as an individual and not on behalf of Caltech.
The Caltech Way
Caltech endorses the well-established peer review systems of our sponsors to identify proposals worthy of funding.
Faculty may not become involved in attempts to influence federal, state or local legislation or draft legislation that includes funding intended for a specific Caltech project ("earmarks"). This includes any efforts to circumvent applicable merit-based or competitive allocation processes.
Caltech Faculty Handbook Chapter 7
Caltech Political & Campaign Activities Policy
9/20/10
1.4 Nepotism
Background
Nepotism is favoritism shown by someone in power to close relatives and friends. Nepotism concerns extend to paid and unpaid appointments on grants and contracts.
The Caltech Way
Caltech discourages situations where employees act as supervisors of close relatives or spouses, or others with whom they have a close relationship outside of the Institute.
No employee should act in any Institute matter involving a member of his/her immediate family including, but not limited to, matters affecting family members' employment or evaluation or advancement in the Institute, without first making full disclosure. Such disclosure should include the nature of the relationship and the impact or potential impact of the employee's action on such family member. Immediate family includes spouse or domestic partner and children. The Provost and, where appropriate, the Vice President for Business and Finance will review all cases.
Caltech Faculty Handbook Chapter 7
Caltech Conflicts of Interest Policy
9/20/10
1.5 Principal Investigator Eligibility
Background
The Principal Investigator (PI) is a single individual designated by Caltech who is responsible for the scientific and technical direction of a sponsored project. Caltech is the official award recipient for sponsored projects and relies upon qualified principal investigators to conduct projects in accordance with the expectations of the Institute and the sponsors of those awards.
The Caltech Way
The privilege to serve as a Principal Investigator is automatically granted to members of the professorial faculty. With a professorial faculty member assuming responsibility for the validity and importance of the research and management of the budget, along with the approval of the Division Chair, and the approval of the Vice Provost for Research, individuals holding the following appointments can serve as Principal Investigator on a sponsored project:
- Senior Research Associate
- Senior Research Fellow
- Faculty Associate
- Senior Faculty Associate
- Members of the Professional Staff
- Members of the Beckman Institute
- Postdoctoral Scholar
Exceptions may be approved by the Vice Provost for Research on the recommendation of the Division Chair.
Caltech Faculty Handbook Chapter 4
Caltech Faculty Handbook Chapter 7
9/20/10
1.6 Principal Investigator Responsibilities
Background
A Principal Investigator (PI) is a single individual designated by the applicant institution who is responsible for the scientific and technical direction of the sponsored project. Caltech, as the official award recipient for sponsored research, relies upon PIs to follow the expectations of the sponsor and the Institute as it pertains to performance, deliverables, financial, and audit requirements.
The Caltech Way
Caltech's Principal Investigators are expected to comply with Institute and sponsor policies and ensure that key members of the research team are also aware of project-related requirements. The PI's signature on the Division Approval Form that accompanies a proposal through its Caltech approval process signifies the PI's acceptance of these obligations.
Principal Investigators (PIs) and other key project personnel are expected to conduct projects in accordance with the policies and procedures of the sponsor and the Institute. The PI assumes responsibility for ensuring all project personnel are familiar with applicable regulations and policies, and that all required assurances and certifications are filed in a timely manner.
Caltech Faculty Handbook Chapter 7
9/20/10
1.7 Research Misconduct
Background
Research misconduct is defined as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Regulations issued by federal agencies establish a government-wide definition of research misconduct and require a three-stage process to manage allegations of real or perceived misconduct. These requirements respond to congressional and public pressure on the agencies and are applicable to all recipients of federal awards.
The Caltech Way
Research misconduct is historically a rare occurrence, especially at Caltech. However, should an instance arise of either real or apparent misconduct, the Institute must act swiftly and decisively, while affording maximum possible protection both to the "whistle blower" (complainant) and to the accused (respondent).
Caltech policy complies with federal requirements and the federal definition of research misconduct. The policy is not intended to deal with disputes over order of authorship or violation of Institute or federal regulations that do not constitute research misconduct.
Caltech Faculty Handbook Chapter 7
9/20/10