ANR Conflict of Interest

What is a Conflict of Interest?

A conflict of interest is a situation in which the conduct of research could be compromised, or appear to be compromised, by a related financial interest on the part of the PI or Co-PIs.  “Financial interest” is defined as any personal benefit of significant monetary value, including, but not limited to: 

• Salary or other payments received for services
• Equity interests, such as stocks, stock options, or other ownership interests
• Intellectual property rights, such as patents, copyrights, and royalties from such rights, other than royalties received through the University
• Appointment to a position as an officer, director, agent, or employee of a business entity 

Rules regarding conflict of interest apply to all investigators (PI and otherwise) on the project as well as to their spouses, domestic partners, and dependent children.  On projects sponsored by private-sector organizations, any financial interest in the sponsor that occurred within 12 months prior to the date of the funding offer or during the project timeframe constitutes a potential conflict of interest.  University policy prohibits academics, staff, managers, or officials from engaging in any activities that create a conflict of interest between official University activities and any personal interest or obligation.  Because conflicts of interest can arise in the course of an individual’s interactions outside the University, the presence of an actual, apparent, or perceived conflict of interest does not automatically constitute wrongdoing. However, any potential conflicts of interest must be disclosed and managed, and the University has a formal procedure for doing so in compliance with federal and state regulations.  It requires that investigators: 

• Disclose their financial interests and the interests of their spouse/domestic partner and dependent children on the appropriate disclosure form(s)
• Provide updates as the amount and nature of financial interest changes during the period of performance of supported research.  This policy is intended to protect investigators, their sponsored research and other educational and professional activities in which they are engaged, and the University. 

Human subjects and conflict of interest 

Research involving human subjects poses special concern with regard to conflict of interest. For example, the research may involve drugs, equipment, materials, or methods in which the investigators, their domestic partner, or their dependent children have a financial interest.  Such interests may appear to compromise the rights and well being of the research subjects as well as the integrity of the related research, and therefore must be disclosed. For this reason, potential conflicts of interest in research with human subjects are subject to particularly careful scrutiny. Disclosure of conflicts of interest related to research including human subjects is included in the Institutional Review Board procedures for each campus, accessible online http://ucanr.org/humansubject.

Use of the University or ANR name, image, brand, and logo

Association of the University of California or ANR name, image, brand, or logo with commercial interests may lead to a conflict of interest.  For example, in the course of consulting or research, ANR academics may provide professional evaluations of products or services, but care must be taken to avoid identifying the University with the academics’ opinions or conclusions in any public or private reports that may support their own outside financial interests.  Academics must also avoid implying an endorsement on the part of the University or ANR.