This page highlights where individuals can find information on the U.S. National Science Foundation's conflict-of-interest policies and guidelines.
On this page
Information for NSF staff
All NSF staff are required to adhere to high standards of ethical conduct. This includes civil service employees; visiting scientists, engineers and educators; and those working at NSF under the "Intergovernmental Personnel Act."
NSF's success in performing its functions depends on the effectiveness and evenhandedness of its decision-making processes. If an individual's impartiality is questioned because of conflicting outside interests, the decision-making process is compromised. NSF must continually earn the public's confidence in its integrity. To do so, each NSF staff member must endeavor to avoid even the appearance of impropriety.
Conflict-of-interest policies for NSF staff
NSF Manual 15: Conflicts of Interest and Standards of Ethical Conduct summarizes the relevant conflicts statutes and regulations pertaining to NSF staff. NSF staff members must conscientiously follow NSF Manual 15 to comply with the executive branch conflict rules applicable them. If you are a program officer, or you are otherwise involved in handling proposals or administering awards, you should also become familiar with the handout "Avoiding Conflicts in Handling Proposals and Awards."
The NSF Ethics Team is comprised of:
- A Senior Assistant General Counsel who is the agency's Designated Agency Ethics Official (DAEO) and principal ethics counselor.
- Two assistant general counsels who also serve as ethics counselors in the roles of, respectively, the alternate designated ethics official and a deputy ethics official.
The DAEO and the alternate DAEO exercise overall responsibility for NSF's ethics program and act as liaisons to the U.S. Office of Government Ethics. NSF staff who have a conflict-of-interest problem or question and cannot find a clear answer in NSF Manual 15 or other NSF guidance should consult an ethics counselor on the ethics team.
Additionally, three sets of conflicts regulations are especially important in guiding NSF staff:
Information for panelists
As an NSF proposal review panel member, site visitor or committee of visitors member, you are considered a "special" government employee while performing your NSF duties. Below is a summary of the major conflict of interest rules that apply to you as a special government employee. Your careful adherence to these rules should foster public confidence that NSF review processes are not tainted by improper influences.
Individuals serving on NSF review panels, site visits or on a committee of visitors are required to disclose any potential conflicts of interest that may impact or arise during their service via the "Conflict-of-Interests and Confidentiality Statement for NSF Panelists," NSF Form 1230P. Visit NSF's Information for Panel, Site Visit or Committee of Visitor Participants page for more information.
What is considered a conflict of interest?
If any of the situations below apply to you, immediately stop your NSF work and contact your NSF program officer. In some situations, a waiver may be possible, but only with the proper NSF ethics authorization.
Conflicts of interest with institutions/entities
If any of the institutions or other entities below are listed on or involved in a proposal, site visit or other NSF matter on which you are working, you have a conflict of interest:
- An institution or other entity where you are currently employed as a professor, adjunct professor, visiting professor or similar compensated position, including employment as a consultant or advisor.
- An institution or other entity where your spouse, your minor child, someone living in your household, or a business partner is currently employed (e.g., professor, adjunct professor or consultant).
- An institution or other entity that is currently considering you, your spouse, your minor child, someone living in your household or your business partner for employment.
- An entity in which you, your spouse, minor child, member of your household or business partner owns securities.
- An institution or other entity where you were employed within the last 12 months, even if you no longer work there.
- An institution or other entity that gave you an honorarium or award within the last 12 months.
- An institution or other entity where you, your spouse, your minor child, someone living in your household, or your business partner has an arrangement for future employment or reemployment. This includes seeking or negotiating for employment with the institution or other entity.
Individual conflicts of interest
If any of the individuals listed below are listed on or involved in any way in a proposal, site visit or other NSF matter on which you are working, you have a conflict of interest:
- A family member like your spouse, child, sibling, parent or other relative with whom you have a close personal relationship.
- An individual with whom you have a relationship, e.g., close personal friendship, that would cause you or a reasonable person familiar with the relationship to question your impartiality or judgment.
- Your Ph.D. thesis advisor or Ph.D. thesis student, whether current or past.
- An individual with whom you collaborated on a project, book, article, report or paper within the last 48 months.
- An individual with whom you co-authored a book, article, report or paper within the last 48 months.
- An individual with whom you co-edited a journal, compendium or conference proceedings within the last 24 months.
- Your business or professional partner or anyone with whom you seek to have a business, contractual or other financial relationship.
Recognizing the above affiliations or relationships and immediately contacting your program officer is critically important. Under federal criminal law, you may not work on a matter in which you or someone whose financial interests are imputed to you has an interest in the matter. The financial interests of your spouse, minor child or business partner, along with certain organizations, including your employer (e.g., home institution), are imputed to you. This means that the interests of these individuals and entities are treated as your interests. When one of them is involved in a matter, it's as if you, yourself, are involved in the matter. In addition, under federal regulations, you may not work on a matter in which a member of the public may question your impartiality because of your relationship with certain individuals or entities involved in the matter.
For additional standards of ethical conduct that apply to you as a proposal review panel member, site visitor or committee of visitors member, please see the document "Ethics Law and Conflicts of Interest Summary for NSF Panelists, Site Visitors, and Committee of Visitors Members" attached to the "Conflict-of-Interests and Confidentiality Statement for NSF Panelists," NSF Form 1230P, provided to each individual prior to their service for NSF.
Additional resources
The following materials contain information regarding conflict-of-interest statutes, standards of conduct, and NSF's supplemental regulations:
Information for proposers and awardees
When submitting a proposal to NSF, the submitting organization's authorized organizational representative (AOR) is required to complete a certification stating that the organization has implemented and is enforcing a written policy on conflicts of interest.
Additional information can be found in Chapter II of the NSF Proposal and Award Policies and Procedures Guide.
Contact us
If you have any questions about conflicts of interests and NSF, please contact the NSF Office of the General Counsel at:
U.S. National Science Foundation
Office of the General Counsel
2415 Eisenhower Avenue
Alexandria, Virginia 22314
Telephone: (703) 292-8060
coi@nsf.gov