700-10: Disclosure of Financial Interests & Management of Conflicts of Interests, Private Sponsors of Research

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Overview

Requires that principal investigators disclose financial interests in private sponsors of their research and conflict of interests must be assessed, managed and, if necessary, eliminated.

Purpose

Principal investigators must disclose financial interests in private sponsors of their research and conflict of interests must be assessed, managed and, if necessary, eliminated. See Title 2 California Code of Regulations § 18755.

Definitions

An investment* of $2,000 or more in the research sponsor by the principal investigator, his or her spouse, registered domestic partner, or dependent children. *Note: an investment is any direct, indirect, or beneficial financial interest in a business entity including stocks, bonds, warrants, and options, including those held in margin or brokerage accounts. (See California Government Code Section 82034 and Title 2 California Code of Regulations § 18237)

For the purposes of this policy, a financial interest in the sponsor of the research means: A. an equity (ownership) or investment interest;
B. a position as director, officer, partner, trustee, employee of or any other management position;
C. income from the sponsor, including consulting income, aggregating $500 or more in value, received by or promised to the principal investigator within 12 months prior to the time the award is made. (See definition of Income)
D. a gift of fifty dollars (fair market value) or more, or multiple gifts totaling fifty dollars (fair market value) or more.

A voluntary, irrevocable transfer of something of value (e.g., cash, real estate, marketable securities, gifts-in-kind, mineral rights, inventions, patents) without receiving something of value in return at the time of transfer or any time in the future. Includes outright gifts, pledges, trusts, and bequests, but excludes grants from private sources.

A payment received, including but not limited to any salary, wage, honorarium, reimbursement, dividend, or advance. (See California Government Code Section 82030 for more details on what does and does not constitute income).

Non-governmental sponsor of research including private and/or publically held companies, foundations, professional associations and voluntary health organizations.

As defined by the Fair Political Practice Commission Form 700-U, include advances and reimbursements for travel and related expenses, including lodging and meals. A. Travel payments may be classified as gifts or as income, depending on the circumstances.
B. Travel payments are gifts if you did not provided services which were equal to or greater in value than the payments received. (See definition of gift).
C. Travel payments are income if the principal investigator provided services which were equal to or greater in value than the payments received. (See definition of income). When reporting travel payments as income, the principal investigator must describe the services he or she provided in exchange for the payment. (See Form 700-U).

Policy

A. Disclosure

  1. All persons employed by UCSF, who have principal responsibility for a research project funded or supported, in whole or in part, by a contract or grant (or other funds earmarked by the donor for a specific research project or for a specific researcher) from a nongovernmental entity, must disclose any Financial Interest in the sponsor of research.
  2. Disclosure statements must be filed:
    1. before final acceptance of such a contract, grant, or gift; and
    2. when funding is renewed.

B. Review of Disclosures

  1. In the case of a disclosed Financial Interest, the disclosure statement and the research project must be reviewed by the Conflict of Interest Advisory Committee (COIAC) prior to acceptance of the contract, grant, or gift. The committee makes a recommendation to the Executive Vice Chancellor and Provost on a course of action with regard to the proposed funding.

C. Public Access to Information

  1. Disclosure statements are subject to public inspection, upon request, under the California Public Records Act.

D. Department Chairs

  1. Department chairs must disqualify themselves from approving research proposals for projects which are funded in whole or in part by a private sponsor in which they have a Financial Interest.

Responsibilities

References

Subject area

Ethics & Compliance

Policy number

700-10

Responsible office

Office of Ethics and Compliance

Effective

Reviewed