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Institutional Conflicts of Interest (ICOI)

The Drexel University identifies an institutional conflict of interest (ICOI) as:
a situation in which a financial interest of the university (e.g., investments held by the university in a company) or a Covered Official has the potential to bias, or appear to bias, research conducted by its employees or students.

The Office of Research & Innovation is developing a policy for Institutional Conflicts of Interest in Research, which will govern identification, review, and management of potential institutional financial conflict of interest.


Institutional financial interests can be created by gifts, payments, royalty income, or other financial benefits provided to the university from for-profit entities or from equity interest held by the university in the entities.  Examples of institutional financial interests include:

  • Payments resulting from the transfer (licensing) of technology created at the university to an entity, including royalties, milestone payments, and other licensing fees;
  • Right to acquire equity or right to receive an exit, change of control, or liquidation fee resulting from a university investment or the transfer of university technology;
  • Equity in (i.e., ownership of) a company (publicly or non-publicly traded) resulting from the transfer of university technology or from direct investment.
  • Gifts, including gifts-in-kind of goods or services, from a potential sponsor (i.e., a commercial company), from a philanthropic unit of the sponsor, or from an individual affiliated with a sponsor; and 
  • Covered Official relationships where an institutional official receives payments, honoraria, royalties (including those from Drexel), equity, options and warrants, company positions (e.g., board directorships and/or management), or gifts.

A potential ICOI situation arises when the company also sponsors research at the university or manufactures products to be studied or tested at Drexel or under its auspices.  

Financial interests of the university must be identified, disclosed, and reviewed to prevent or manage institutional conflicts of interest that may affect (or reasonably appear to affect) institutional processes for the design, conduct, reporting, review, or oversight of research.  


ICOI management strategies include, but are not limited to:

  • Permitting the research to proceed, subject to a plan for managing the ICOI and any personal conflicts of interest (COI); 
  • Permitting the research to proceed, with divestiture of the financial interests of the university and individual investigators; or
  • Prohibiting the research from taking place at the university.

As a Drexel employee, you are expected to comply with the university's policies, guidance and procedures regarding ICOI.  Should an ICOI situation exists for a company that sponsors your research, you will be expected to review and take action on an ICOI management plan.  This may include disclosing the university's financial interest to the study team, in publications, and/or in informed consent documentation.

For questions related to ICOI, please contact

What is a Covered Official?

A Covered Official of the University is an executive officer, dean, or institute/center director with day-to-day responsibility for the supervision of faculty and staff participating in research conducted at or under the auspices of the University.

What is the Difference between COI, ICOI and OCI?

Conflicts of Interest (COI) represent financial or other situations where an individual has an outside interest (e.g., equity in a company, intellectual property, consultant activity with a company) that could affect the design, conduct or reporting of their research.  Also referred to as personal or individual COI.
Institutional conflicts of interest (ICOI) represent financial or other situations where the University, as an institution, has an outside interest (e.g., equity in a company doing business with the University) that could affect the design, conduct, reporting, review or oversight of research conducted by its employees or students.

Organizational conflicts of interest (OCI) represent situations where an individual's service or work on behalf of a U.S. government agency or other funding sponsor may provide the University, as an institution, an unfair competitive advantage when other University members apply for a funding opportunity with that agency or sponsor.