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Conflict of Interest Policy

March 25, 2011

Josho Gakuen Education Foundation Conflict of Interest Policy

Ⅰ Purpose

Josho Gakuen Educational Foundation (hereinafter referred to as "Josho Gakuen") establishes the Conflict of Interest Policy here to clearly show within and outside Josho Gakuen its basic approach to and management policy of social contribution activities, such as industry-government-university collaboration and technology transfer (hereinafter referred to as "Social Contribution Activities"), which Josho Gakuen Headquarters, Osaka Institute of Technology, Setsunan University, and Hiroshima International University (hereinafter referred to as "Group Universities") promote. Staff members who engage in these activities are requested to always keep this policy in mind when conducting such activities.

Josho Gakuen's Social Contribution Activities include a wide variety of activities, such as joint research, contract research, consulting (including technical guidance), licensing of intellectual property rights, support for analysis and measuring activities by using facilities and equipment of the Universities, and the provision of extension courses. However, the primary responsibility of the Universities lies in the development of professional specialists as clearly stated in goals of foundation. Therefore, Josho Gakuen and the Universities should take utmost care that over commitment of the faculty to the Social Contribution Activities would not limit the students' opportunities to receive education or prevent the development of their uniqueness and their academic pursuits.

The purpose of the Conflict of Interest Policy laid out here is not to limit the Social Contribution Activities by the faculty, but to provide guidelines that enable Josho Gakuen and the Universities to build a management system for conflict of interest and thereby conduct Social Contribution Activities in a proper and smooth manner.

Ⅱ Definition

Terms used herein are defined as follows:
  1. Conflict of Interest shall mean the condition of conflict between the responsibilities and duties required of the faculty, et al., of Josho Gakuen or the Group Universities and the interest they obtain from their Social Contribution Activities.
  2. Conflict of Responsibilities shall mean the condition of conflict between the responsibilities and duties required of the faculty, et al., of Josho Gakuen or the Universities and their responsibilities in Social Contribution Activities.
  3. The situations of the above paragraph 1 and 2 shall mean a conflict of interest in the broad sense of the term.
  4. Conflict of Interest Management shall mean the rules and application methods to make the faculty, et al., feel safe in engaging in Social Contribution Activities.

Ⅲ Basic Approach to Conflict of Interest Management

  1. In light of the Universities' role in education, research, and Social Contribution Activities, Josho Gakuen believes that one of its responsibilities is to promote Social Contribution Activities by the faculty, et al., to the extent that their Social Contribution Activities do not interfere with their education and research activities.
  2. The Conflict of Interest Management Committees established by Josho Gakuen shall actively encourage technology transfer of inventions, the results of the Universities' academic research activities, to industries while preventing the faculty, etc. from getting involved in conflict of interest situations and taking appropriate measures to solve such situations, once occurred in an effort to implement activities for the promotion of Social Contribution Activities in an efficient manner.
  3. In compliance with this policy, the Conflict of Interest Management Committees of the Universities shall take appropriate steps to solve each specific conflict.
  4. The faculty, et al., shall be held responsible for not causing conflict of interest situations when engaging in Social Contribution Activities.

Ⅳ Applicatio and applicable Events of Conflict of Interest Management and Criteria for Problem-Solving

  1. Applicable Persons
    (1)Full-time teaching staff and administrative staff
    (2)Specially appointed faculty, visiting faculty and temporary administrative workers, who are engaged in industry-government-academia collaboration activities
    (3)Board members and trustees who engage in Social Contribution Activities in accordance with their positions in Josho Gakuen
  2. Criteria for Problem-Solving
    (1)Concurrent Job Handling Requirements shall be applied to the criteria to allow full-time faculty members (including quasi-full time specially appointed faculty members) to have a concurrent job outside Josho Gakuen. Even if the faculty, et al., fulfill the requirements for an outside concurrent job, they should not look, when viewed objectively, that their individual interest via Social Contribution Activities has priority over their work at the Universities.
    (2)Even for cases where a permit for an outside concurrent job is not required, if the following apply, care should be taken so that any situations involving conflicts of interest or conflicts of responsibilities may not arise.
    (a)When interacting with outside organizations through joint research, contract research and the acceptance of research workers;
    (b)When giving a facility to partners of joint research or contract research or when purchasing goods from those to whom the facility has been given;
    (c)When personally receiving considerable remuneration from one corporate body in return for a lecture.
    (d)When personally receiving considerable remuneration from one corporate body by becoming a committee member of an outside organization, such as a national/local public agency or an academic society;
    (e)When receiving donations, equipment, and/or goods from outside organizations;
    (f)When giving permission to use the facilities or equipment of the Universities;
    (g)When receiving facility from outside organizations or when such provision is feasible;
    (h)When transferring or licensing own intellectual property rights to an outside organization;
    (3)Whether or not personal benefits are obtained, care should be taken so that faculty members may not objectively be looked upon as spending more time and effort in Social Contribution Activities (including work as a part-time instructor) than in work at the Universities.

Ⅴ Conflict of Interest Management Structure

  1. Conflict of Interest Management Committees In an effort to properly handle conflicts of interest arising out of Social Contribution Activities, including industry-government-academia activities, Conflict of Interest Management Committees are established at Josho Gakuen and the Universities. These committees will deliberate the following issues related to conflicts of interest, discuss the countermeasures, and strive to enhance the faculty's awareness of such situations:
    (a)Measures for conflict of interest management
    (b)Determination of admissibility of issues arising out of behavior that gave rise to a conflict-of-interest situation
    (c)Establishment, improvement, and discontinuation of rules, etc., regarding conflicts of interest
    (d)Consultation, advice, and guidance regarding conflicts of interest
    (e)Investigation, improvement guidance, and recommendations regarding conflicts of interest
    (f)Disclosure of conflicts of interest information to society
    (g)Education activities regarding conflicts of interest
    (h)Other issues related to conflicts of interest
  2. Establishment of Adviser
    In order to facilitate smooth conflict of interest management, Josho Gakuen set up Adviser at the Group Universities comprising outside and legal specialists, who will give advice on conflicts of interest from a professional point of view.

Ⅵ Conflict of Interest Management Procedures

  1. Those people to whom the Conflict of Interest Policy is applied are required to report information regarding conflicts of interest that have arisen out of Social Contribution Activities to the Conflict of Interest Committee at the relevant University.
  2. Information submitted by the faculty, et al., will be selected, recorded, and stored in accordance with Josho Gakuen's rules for the protection of personal information.
  3. Details of procedures for conflict of interest management will be established separately.

Ⅶ Effective Date and Review Schedule

This policy shall be effective on April 1, 2011.