Skip to main content

What to Disclose?

Disclosure of outside professional activities and financial interests that relate to your role(s) and responsibilities at Northwestern is required by Northwestern's Policy on Conflict of Interest and Conflict of Commitment.

If you are involved in federally or industry sponsored research, or research submitted to the IRB, the Conflict of Interest in Research also applies, which requires disclosure of Significant Financial Interests (SFIs).

 

General guidelines for staff members

What do I need to disclose?

  • Relationships and activities that are related to your job at Northwestern
  • Any gift(s) from a company that is doing business - or trying to do business - with Northwestern
  • If you have a relationship with a company or organization that gave a gift to Northwestern, that should also be disclosed
  • Financial interests in an organization that is related to your role at Northwestern, or that does business with Northwestern to the best of your knowledge

What should not be disclosed?

  • Any activity or relationship that does not use Northwestern resources and is unrelated to your job at Northwestern

Example situations common to staff members

A freelance photography / web design / graphic design business should be disclosed if...

  • Part of your job includes photography / web design / graphic design
  • A department at Northwestern is a client of your freelance business
  • You use Northwestern resources (e.g., equipment or software) in your freelance business

Volunteer activities in your community likely do not need to be disclosed unless...

  • You use Northwestern resources to perform the activities.  For example, routine use of a copier machine or printer to create flyers, use of software or other Northwestern resources for those activities

Selling cosmetics or clothing as an independent representative likely does not need to be disclosed unless...

  • You sell products to your department / unit
  • You work in a department where you are in charge of purchasing cosmetics / clothing
  • You purchase products from your outside business for your Northwestern work

A family-owned pizzeria likely does not need to be disclosed unless...

  • You purchase pizza for department functions from the pizzeria
  • You refer other departments at Northwestern to the pizzeria
  • You work in a taste research group that is working on developing a better sauce

General guidelines for faculty

What do I need to disclose?

  • Relationships and activities that are related to your Northwestern responsibilities (teaching, research, service on committees)
  • Financial interests in an organization that is related to your work at Northwestern - consulting, advising, speaking, etc. if the organization is related to your field and/or could benefit from your professional expertise
  • Ownership of, or investment in, a start-up company related to your field even if it is just "on paper" or worth nothing
  • Use of Northwestern resources for outside activities - including staff, software, equipments, space or confidential information
  • Academic appointments outside of Northwestern

What does not need to be disclosed?

  • Service on an NIH study section, or NSF grant review panel does not need to be disclosed.  Service for federal sponsors is exempt from disclosure
  • Mutual funds or other retirement holdings do not need to be disclosed
  • Grants or sponsored research funding you have received while at Northwestern that went through the sponsored research office do not need to be disclosed
  • Activities or relationships that are unrelated to your field and/or work at Northwestern

Example situations common to faculty members

An invited lecture at another academic institution likely does not need to be disclosed...

  • One-time invited lectures or speaking engagements for an academic institution do not need to be disclosed
  • If you taught an entire course at another institution and/or received an appointment at the institution, that should be disclosed

 

Do I need to disclose every stock I own?

No.  The disclosure form asks about ownership & equity holdings but excludes:
  • Anything not related to what you do at Northwestern
    • Example: Owning stock in Google likely does not need to be disclosed unless:
      • You are teaching a class on developing search algorithms, or
      • You do research on how a person’s search history can inform advertising such that your work is related to Google’s mission.
  • Anything in your retirement accounts or in a managed portfolio where you are not responsible for deciding what accounts to invest in.

Examples of when it would be appropriate to disclose stock in a publicly traded company (e.g., Pfizer) include:

  • Conducting research sponsored by Pfizer in your lab, or
  • Participating as an investigator in Pfizer clinical trials.

A start-up company needs to be disclosed when…

Within 30 days of:

  • Acquiring any ownership interest (options, shares, etc.) in the company,
  • Investing in the company, and/or
  • Filing paperwork with the Secretary of State as a founder.

While we understand that this new company may be just “on paper” and may not have value yet, as soon as the company is formed (i.e., it is incorporated and registered with the Secretary of State), it is a legal entity and, legally, exists. 

Updates are expected of all faculty per the Policy on Conflict of Interest and Conflict of Commitment, but faculty who are engaged in research subject to the Conflict of Interest in Research policy, are required to update if a start-up company is formed.  This is because federal regulations consider any ownership interest in a non-publicly traded entity to be a significant financial interest.  Being a founder, investor, or having any other ownership stake in the company all meet this definition.

See Completing a Disclosure for instructions to log into eDisclosure and update.