It is very common for researchers to engage in professional activities outside of WashU. Most of these activities do not present concerns for the university or funding agencies, provided they are properly structured and disclosed.
It is important to be fully honest in all disclosures. Even if an activity does not feel relevant to disclose, it is relevant to the university and funding agencies.
External Professional Activities and Interests
Requirements for disclosing to the university are covered in the External Professional Activities Policy, Prior Approval Guidance, and Financial Conflicts of Interest training.
- External Professional Activities associated with any international entity (government, non-profit, for-profit, university/academic), must be disclosed.
Funding agencies typically have their own reporting and disclosure requirements. These commonly include:
Documents such as the Biosketch and Current and Pending (Other) Support
Report external activities, research activities, and international activities. For more information, visit the NIH and NSF disclosure pages.
Certifications of no engagement in maligned foreign talent programs
Review the Guidance for Foreign Talent Programs page on the COI website.
Foreign components
Activities that contribute to a specific aim of your grant. Examples (adapted from the NIH):
- Collaborations with investigators at a foreign site anticipated to result in co-authorship
- Using facilities or instruments at a foreign site
- Receiving financial support or resources from foreign entity
- Involving human subjects or animals
- Extensive foreign travel for the purpose of data collection, surveying, sampling, etc.
Funding agencies may use disclosed information to perform risk assessments to identify and counter foreign influence.
Personal Agreements with an External Entity
The University does not formally review and approve your personal agreements/contracts; however, the External Professional Activities Policy requires prior approval for these activities. There are aspects of an agreement you should be mindful about when partnering with a foreign entity that you may not experience with a domestic entity. Refer to Guidance for Personal Agreements for a list of examples and best practices.
Some entities may be considered a restricted party, which could prohibit or limit certain activities with an entity (or country or person). A consolidated screening list search engine available online. The University can also provide a more comprehensive screening by contacting the export control office at ovcrexportcompliance@wustl.edu.
Questions?
If you are ever unsure if something should be disclosed, it is best to ask the Conflicts of Interest (COI) office.