CHAP: Conflict of Interest Policy

Purpose

It is NCAR policy that the Computational and Information Systems Laboratory (CISL) HPC Allocations Panel (CHAP) procedures for evaluating National Science Foundation (NSF) computational resource requests are fair and equitable to all requestors, and protect the integrity of the research, science, the NSF and NCAR. Recommendations are to be based on objective judgments of merit without regard to subjective personal biases. The guidelines and ethical standards presented here provide a framework by which conflict of interest (COI) situations can be identified and resolved, thus minimizing the level of personal bias in the provision of high performance computing resources to the NSF community.

A conflict of interest is a clash between an individual’s concern for the public interest or the best interest of NCAR and his or her private interests or allegiances. Conflicts of interest, actual or perceived, may compromise NCAR's integrity and standing in the research community, its sponsors, and the professional reputations of individuals. They also compromise the effectiveness of the decision-making process by warping and biasing such effectiveness. As such, conflicts of interest must be scrupulously avoided.

Individuals involved with CHAP activities shall act impartially and not give preferential treatment to any individual or organization, may not use their position on CHAP or knowledge gained through CHAP activities, to obtain a personal advantage either for themselves or for any other person or entity in whom or in which they have a financial or other vested interest. Potential and actual conflicts of interest, or the appearance of such, must be managed so that NCAR’s assessment process is not compromised, research conducted through NCAR is free from bias, the investment of the public is protected, and confidence in the integrity of NCAR’s activities is maintained.

Conflicts of interest are common and even inevitable, so that a disqualification to review should be understood to be a positive solution and in no way is a reproach. Whether particular circumstances create an appearance that the ethical standards outlined in this document have been violated shall be determined from the perspective of a reasonable person with knowledge of the relevant facts.

Responsibilities of members

Appointment as a CHAP member requires awareness of COI situations that may arise during the evaluation of resource requests.

Conflicts of interest may arise, for example, in the following situations: professional and personal relationship with a requestor or requestor’s department; use of inside information or access to such information; financial, investment, or other ownership interests; use of confidential information; subcontracts with employees, their immediate families, and their business associates; work with UCAR/NCAR contractors; involvement in legal actions against the Federal government and other sponsors; improper use of the UCAR or NCAR name or affiliation; and improper use of NCAR facilities and resources.

The procedures followed with regard to COIs and CHAP activities are those of Disclosure, Avoidance, and Removal.

Disclosure

Prior to the assignment of reviewers, CISL will summarize all known COI’s for the CHAP chair (Chair). In some instances, a COI is known only to the individual panel member. Each panel member is responsible to declare immediately each COI and to bring the matter promptly to the attention of CISL and the Chair. The Chair, acting as an objective, disinterested third party, determines how the matter should be handled and additional steps, if any, to take. Simply stating and documenting the existence of a conflict of interest does not suffice to eliminate it. A written record of how each conflict was resolved for each CHAP panelist shall be compiled by the Chair as part of the official record of the meeting.

Avoidance

Members should avoid all conflicts of interest or the appearance of such. In the course of their duties with CHAP, members should avoid situations in which they can influence or appear to influence a decision or course of action, as well as any actions that may give monetary gain or personal benefit to themselves or to those with whom they are associated professionally and personally, as covered under the relationships discussed infra.

Removal

In those instances in which a CHAP member is a Requesting Scientist on a resource request for the current panel meeting, or a Principal Investigator (PI), or Co-Principal Investigator (CO-PI) on the NSF award supporting the resource request, the resource request will be evaluated and a resource allocation recommendation will be made to the CISL Director of Operations and Services prior to the panel meeting. The resource request will be discussed via email or via a teleconference involving those panelists without a COI on any of the requests being discussed. In instances where the Chair has judged that a COI exists for a CHAP member who is not a PI, CO-PI, or Requesting Scientist for a proposal being considered, or if there is a need for further discussion of a request that was reviewed in advance to balance the resources allocated, the conflicted panel member shall physically leave the room during discussion of the proposal. In other instances in which a COI is disclosed, and the Chair has judged it to be minor, the panelist may continue to participate in the discussions.

Examples of conflict of interest situations

Conflicts of interest exist for any of the relationships below:

  1. Affiliations with a requestor’s institution:
    • Current employment (formal or informal) within the same department or institution. In case of UCAR/NCAR employees, conflicts exist within the same division, institute or laboratory.
    • Any affiliation with the requestor institution including, but not limited to, current membership on a visiting committee or similar body at the requestor’s department, holder of any office, governing board membership, or relevant committee chairpersonship in the requestor’s department.
    • Currently seeking employment with the institution.
  2. Relationships with an Investigator or other person who has a personal, academic and/or financial interest in the request and/or proposal:
    • Known family or marriage relationship.
    • Business or commercial partnership.
    • Present association as primary thesis advisor or thesis student or past association in such a capacity over the last ten years.
    • Professional collaboration involving research and publication over the past four years or as Principal Investigator and Co-Principal Investigator on a current resource request.
  3. Other relationships with the requestor or the request. The interests of the following persons are to be treated as if they were the panel member’s own:
    • Any relationship, such as close personal friendship that might affect the member’s judgments, or be seen as doing so by a reasonable person familiar with the relationship.
    • Any other conflicts known to the panel member that would prevent him/her from reviewing a project in a non-biased, fair and objective way.

CHAP participants are encouraged to seek guidance on these conflict of interest guidelines at any time. For UCAR/NCAR employees other policies may apply, including: Conflict of Interest (1-1-4), Ethical Conduct (1-1-23), and Investigator Financial Disclosure (1-1-27).

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