Ethics Information for Prospective Senior Employees

If you're interested in a senior position at NIH, there are ethics statutes and regulations governing the activities of senior federal employees. If you agree to accept a senior position, you're subject to the following:

The NIH Ethics Office (NEO) is your source for general ethics information.

Visit the NIH Ethics Program site

Real and apparent conflicts of interest

  • You must comply with value limits on stock/stock options and sector fund ownership in the pharma, biotech, medical device, and/or healthcare industry applicable to senior employees, their spouses, and minor children
  • You must recuse from NIH work that could affect a real or potential royalty stream from a non-NIH developed technology
  • You must file a public financial disclosure report detaining financial holdings and certain outside interests, including those of the spouse and dependent children
  • You must recuse from NIH work that could involve or affect the spouse's employer or clients, or affect the spouse's financial interests

Read more on Conflict of Interest (NEO)

Outside (non-NIH) activities

  • Certain outside (non-NIH) activities are prohibited, and most require prior approval, so seek advice early and do not engage in the activity until approval is granted
  • If you own a business that does consulting work with NIH, you may be required to close the business, cease seeking business from the NIH, or end the outside position
  • The Emoluments Clause restricts most gifts, compensation, positions, and titles with foreign governmental entities
  • The Hatch Act limits certain political activities of federal employees

Read more on Outside Activities (NEO)

Former employer

  • A one-year "cooling off" period prohibits new employees from working on NIH matters involving or affecting the former employer for their first year
  • You must step down as Principal Investigator prior to the NIH start date and prior approval is required to wrap up research (i.e., publish a manuscript) or to continue collaboration on the project through an NIH lab
  • NIH approval is needed for commitments with organizations made prior to onboarding (speaking engagements, thesis committees, etc.)

Read more on "Cooling Off" Periods (NEO)