Aaron Diamond AIDS Research Center

The Aaron Diamond AIDS Research Center's Policy on
Financial Conflict of Interest and Conflict of Commitment in Research

Financial Conflict of Interest

Introduction

The objective of this Policy is to maintain the integrity and transparency of financial relationships related to investigators' research at The Aaron Diamond AIDS Research Center ("ADARC"). To accomplish our purpose, all investigators (defined below), regardless of title or position and irrespective of funding source, are expected to complete a Significant Financial Interest Disclosure Form at least annually, disclosing all of their Significant Financial Interests ("SFI") (defined below).

Investigators who are responsible for the design, conduct, analysis or reporting of research are required to disclose their SFI prior to submitting a federal Public Health Service grant application. By requiring all investigators routinely to complete financial disclosures, ADARC can assure that no grant will be withheld from submission due to a disclosure failure.

Investigators must update disclosures within thirty (30) days of discovering or acquiring any new SFI.¹ If an investigator's Significant Financial Interest Disclosure Form reflects a financial conflict of interest, assistance will be provided to eliminate, reduce or manage the conflict.

Conflicts in research involving human participants will be managed differently than conflicts arising in other research.²

Definitions

ADARC's definitions of the following terms track the federal regulatory definitions.

Financial conflict of interest
A financial conflict of interest exists when an investigator's Significant Financial Interest could directly and significantly affect the design, conduct, analysis or reporting of the investigator's research.

Significant Financial Interest

________________________

1	This disclosure will not substitute for the required statements that accompany Institutional Review Board filings. Howard Hughes Medical Institute (HHMI) Investigators will continue to meet separate HHMI disclosure requirements
2	The Rockefeller University Human Research Protection Program describes the Hospital's conflict of interest standard and process governing research involving human subjects.