Omnibond Investigator Conflict of Interest Policy
Last Updated November 2020

Omnibond has formulated the Omnibond Conflict of Interest Policy for Federal research to identify and address real and apparent financial conflicts of interest in research with the goal of preventing personal interests and activities from adversely influencing Omnibond and our research partners.

Investigators have an obligation to act in the best interest of the Omnibond and its research partners and their missions and must not let outside activities or significant outside financial interests interfere with those obligations. This policy is intended to increase awareness of research personnel to the potential for conflicts of interest and to establish procedures whereby such conflicts may be avoided or properly managed.

Principles and procedures, outlined in this policy, assure that research personnel will report external commitments and financial interests in a timely manner and real and apparent conflicts will be identified and responsibly managed.

Omnibond’s and its research partners have a responsibility to actively participate in research, and economic development, even if conflicts of interest are more likely and many times unavoidable. Conflicts of interest, therefore, may arise from ordinary and appropriate activities as a part of assigned employment duties so the existence of a conflict should not imply wrongdoing. When conflicts of interest do arise, however, they must be recognized and disclosed, then eliminated or appropriately managed. Omnibond’s leadership has a duty to govern in a manner such that conflicts are appropriately reviewed and acted on to maintain confidence in the integrity of our company.

This policy applies to all personnel who actively participate in Federal or State funded research. For the purpose of this policy, personnel refers to the following: Omnibond personnel and others identified at the time of proposal submission as having potential for a conflict of interest related to a research activity that involves their activity. This includes all full-time, part-time, regular FTE, temporary, and contract personnel and others acting on Omnibond’s behalf in the performance of Omnibond-related research.

This policy promotes compliance with all applicable federal and state laws, regulations, and policies regarding conflicts of interest. Nothing in this policy shall be construed to permit, even with disclosure, any activity that is prohibited by law.

Public Health Service (PHS)/National Institutes of Health (NIH) Funded Research: Omnibond research personnel who seek to conduct federally-funded research (including PHS/NIH funding) or are funded by a federal agency are subject to the federal policy governing that agency’s in addition to the Omnibond’s Conflict of Interest Policy. Any conflict of interest subject to this Policy shall be reviewed and managed pursuant to the requirements of the applicable federal agency’s policy.

Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards: This policy is intended to comply with the requirements of 2 CFR 200.318 as applicable to Omnibond. Principles Objectivity and integrity in decision-making: Omnibond personnel participating in research are obligated to make decisions that are in the best interest of company and its research partners, free from any conflict that might place personal interests ahead of the public interest. Transparency in relationships with external communities: Activities with outside enterprises and other economic activities of the company itself should be conducted so as to maintain public confidence in the company.

Commitment to oversight and management: Omnibond’s leadership and administration must be aware of and deal appropriately with potential conflict of interest situations, both real and perceived, which may arise in connection with outside activities. All Omnibond personnel are obligated to disclose any interests that may be potential conflicts and the company is then responsible for providing a conflict of interest management process that protects the interests of personnel, the company and the public.

Omnibond personnel who violate this policy are subject to disciplinary action, up to and including termination.