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Introduction

Federal regulations and institutional policy require that all persons responsible for the design, conduct or reporting of a proposed research project, contract, sub-contract, agreement or protocol must disclose Significant Financial Interests (SFIs) that reasonably appear to be related to their institutional responsibilities. This requirement extends to collaborators, postdocs, students, residents, and consultants.  

When are disclosures required?

  • At the time a project is proposed (new grant submission, new contract executions, new protocol submissions)
  • Annually
  • Within 30 days of acquiring any new Significant Financial Interest.

Determining what you must report

If ANY of the following apply to you, answer “YES” to the statement at the bottom of this page.

In the 12 months preceding this disclosure, have you or your family members had a Significant Financial Interest (SFI) in ANY:

Publicly-Traded Entity 
in which your combined equity value (ownership of stock, options, etc.) AND income exceeded $5,000 and that entity appears to be related to your institutional responsibilities;

Non-Publicly-Traded Entity   

in which you had an ownership interest of ANY value OR income exceeding $5,000 (from any one entity), and that entity appears to be related to your institutional responsibilities;

Intellectual Property   
from which you received ANY income, and the intellectual property appears to be related to your institutional responsibilities;

Sponsored Travel

paid for, or reimbursed directly to you, by any organization OTHER THAN an accredited, U.S. institution of higher education (including LLUH) or any U.S. government agency (federal, state, or local); and the purpose of the travel or the sponsoring organization appears to be related to your institutional responsibilities; and the dollar value of the travel in the aggregate from this sponsor exceeds $5,000 in the last 12 months;

A Paid Position of Influence 

in which you had any authoritative or direction-shaping role in any entity NOT affiliated with LLUH (including non-profit organizations) and the interests of the entity appear to be related to your institutional responsibilities.

For Procurement Conflict of Interest

Introduction

The Procurement Standards in the Uniform Guidance of the Federal Code of Regulations (2 CFR 200.318(c)(1)) requires that no employee, officer, or agent must participate in the selection, award, or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. The officers, employees, and agents of the non-Federal entity must neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.

When are disclosures required?

You are obligated to provide a new or updated disclosure

  • Annually
  • Promptly upon acquiring any actual or potential conflict of interest

Determining what you must report

If ANY of the following apply to you, answer “YES” to the statement at the bottom of this page.

  • You or any member of your immediate family, your partner, or an organization which employs or is about to employ any of the parties indicated herein, have a financial or other interest in or a tangible personal benefit from a firm that could be considered for a procurement contract.

In your role at LLUH, you make purchasing decisions or otherwise influence the organization’s decision to do business with a supplier/contractor affiliated with you or your immediate family members or any other individual who would be perceived as a potential conflict.