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conflict of interest


Significant Financial Interest means a financial interest consisting of one or more of the following interests of the investigator (and her/his spouse and dependent children) that reasonably appear to be related to the investigator's institutional responsibilities:

  1. Publicly traded entities: (a) remuneration (e.g., salary, consulting fees, honoraria, paid authorship) from the entity in the 12 months prior to disclosure; and/or (b) equity (e.g., stock, stock options, other ownership interest) held as of the date of the disclosure that (c) when combined (remuneration + equity) exceeds $5,000;

  2. Non-publicly traded entities: (a) all remuneration from the entity in the 12 months prior to disclosure that, when combined, exceeds $5,000 and/or (b) any equity interest in the entity;

  3. Receipt of income in excess of $5,000 received in the 12 months prior to disclosure through intellectual property rights and interests (e.g., patents, copyrights) from any source other than ADARC, Rockefeller University or HHMI;

  4. Travel: any reimbursed or sponsored travel (i.e., that is paid on behalf of the investigator and not reimbursed to the investigator so that the exact monetary value may not be readily available), but not including travel reimbursed or sponsored by: a federal, state or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. institution of higher education.

Significant Financial Interest does not include

  • Salary, royalties or other remuneration from The Aaron Diamond AIDS Research Center or HHMI;
  • Income from investments such as mutual funds or retirement accounts so long as the investigator does not directly control these vehicles' investment decisions; or
  • Income from seminars, lectures, teaching engagements, service on advisory committees or review panels for a federal, state or local government agency, a U.S. institution of higher education, an academic teaching hospital, a medical center, or a research institute affiliated with a U.S. institution of higher education.

Investigator
Investigator means any person in or collaborating or consulting with a laboratory, regardless of title or position, who is responsible for the design, conduct, analysis or reporting of research.3

Institutional Responsibilities
Institutional responsibilities means an investigator's professional responsibilities on behalf of the ADARC which may include, for example, activities such as research, research
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3 If research is done on behalf of ADARC through institutional subrecipients, subgrantees, subcontractors, consultants or collaborators, those institutions having a written agreement with ADARC must ensure that the institution (i) has a written, enforced financial conflict of interest policy that is compliant with federal requirements, or (ii) in the absence of a written enforced policy, the institution will comply with applicable federal mandates.