The CRDF requires that all Project Directors/Principal Investigators and Principal Institutions (hereafter collectively "Grantees") adhere to the highest ethical standards in all matters related to the CRDF award. CRDF policy prohibits Grantees from participating in specific CRDF decisions and dealings when the Grantee knows that any of his/her relationships, including those of a member of his/her immediate family, may pose a conflict of interest with respect to a specific CRDF transaction; and requires disclosure of any relationships known to the Grantees which are covered by this policy and which may affect improperly the CRDF transaction.

In accordance with this policy, Grantees will:

• Disclose promptly to the CRDF Representatives identified in this Project Agreement any relationship of which the Grantee has knowledge that pertains to any transaction of CRDF that may be covered by this policy.

• Refrain from participating in decisions to authorize a transaction when involved in a relationship covered by this policy affecting the transaction except:

                 (1) To provide information when requested, or

                 (2) To provide information known to the consultant/contractor indicating that a 
                      proposed or existing transaction could be contrary to this policy

• Refrain from dealing on behalf of CRDF with organizations or persons on transactions covered by this policy, except after full disclosure and with the express written authorization of the CRDF Award Administration Representative identified in this Project Agreement or his/her authorized designee.

CRDF Grantees are expected to monitor their relationships on an ongoing basis and to report any relationships that might violate this policy.

Examples of situations that violate this policy include, but are not limited, to:

• Participation of a Principal Investigator/Project Director in the selection of a vendor with which the Principal Investigator has a relationship subject to this policy.

• Selection of a vendor by a Principal Organization in which the Principal Organization has an ownership or controlling interest or stands to benefit financially through the transaction.

• Inclusion of members of the immediate family of the Principal Investigator/Project Director as recipients of financial support under the CRDF award.

Failure to strictly comply with this policy may result in the immediate termination of this Project Agreement and the return of all funds to CRDF, whether expended or unexpended.

For the purposes of this policy, the following definitions apply:

"Interest" and "having an interest" shall mean a relationship of any kind in which a person or organization is deriving a pecuniary or in-kind benefit from the person or organization with which CRDF is initiating, selecting, authorizing or implementing a transaction.

"Members of the immediate family" shall mean persons related lineally to the Grantee, e.g. grandparents, parents, children, grandchildren, etc., or to the Grantee's spouse as well as siblings of the Grantee, or the spouse of their lineal relatives.

"Organization(s)" shall mean any partnership, group, association, organization, or governmental agency, whether or not formally registered or incorporated or otherwise publicly recognized under the laws of any country.

"Person(s)" shall mean any individual or individuals whether or not they are employees, members, or otherwise associated with any organization covered by this policy.

"Transaction(s)" shall mean any commitment or legally binding obligation of the CRDF with another person or organization.

Policy Last Reviewed: 02/2003

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