Outside Interests: Significant Financial, Personal and Foreign Interests

Below, please find a list of the potential points of disclosure. 

COC Form – Outside Activity

If your seminars meet the definition of Outside Commitment, you should submit a COC form in eDisclosure to get prior approval to engage in the Outside Activity.

Outside Commitments: (1) are professional and other activities that are related to a University Employee’s professional expertise, outside of their University duties and responsibilities; (2) are for the benefit of an external entity or individual and are not covered by a fully executed written agreement between the University and the external entity; and (3) require a time commitment. Outside Commitments include Outside Employment, independent contracts for consulting services, private consulting groups comprised of University Employees, volunteer/pro bono work, appointments at postsecondary educational institutions, and foreign components, as that term may be updated by the University’s Office for Responsible Outside Interests.

You can also use this decision tree to determine if the activity is an Outside Commitment: Outside Commitment Decision Tree.

COI Disclosure – Foreign Interests

If you do end up receiving a payment of any amount, an in-kind contribution or Other Support, it must be disclosed as a Foreign Interest.

COI Disclosure – Foreign Travel

PHS and Dept of Energy Investigators only: Must disclose any reimbursed or sponsored travel related to your institutional responsibilities, regardless of the amount, unless received from a Federal, state, or local government agency of the United States; a domestic Institution of Higher Education; or a domestic research institute that is affiliated with a domestic Institution of Higher Education.

COI Disclosure – Foreign Affiliations

As part of your eDisclosure submissions, you must disclose whether you have a foreign affiliation.

Below, please find a list of the potential points of disclosure. 

COC Form – Outside Activity

If any of your activities during your travel meet the definition of Outside Commitment, you should submit a COC form in eDisclosure to get prior approval to engage in the Outside Activity.

Outside Commitments: (1) are professional and other activities that are related to a University Employee’s professional expertise, outside of their University duties and responsibilities; (2) are for the benefit of an external entity or individual and are not covered by a fully executed written agreement between the University and the external entity; and (3) require a time commitment. Outside Commitments include Outside Employment, independent contracts for consulting services, private consulting groups comprised of University Employees, volunteer/pro bono work, appointments at postsecondary educational institutions, and foreign components, as that term may be updated by the University’s Office for Responsible Outside Interests.

You can also use this decision tree to determine if the activity is an Outside Commitment: Outside Commitment Decision Tree.

COI Disclosure – Foreign Interests

If you do end up receiving a payment of any amount, an in-kind contribution or Other Support, it must be disclosed as a Foreign Interest.

COI Disclosure – Foreign Travel

PHS and Dept of Energy Investigators only: Must disclose any reimbursed or sponsored travel related to your institutional responsibilities, regardless of the amount, unless received from a Federal, state, or local government agency of the United States; a domestic Institution of Higher Education; or a domestic research institute that is affiliated with a domestic Institution of Higher Education.

COI Disclosure – Foreign Affiliations

As part of your eDisclosure submissions, you must disclose whether you have a foreign affiliation.

Below, please find a list of the potential points of disclosure.

COC Form – Outside Activity

If your visits or seminars to Japanese universities meet the definition of Outside Commitment, you should submit a COC form in eDisclosure to get prior approval to engage in the Outside Activity.

Outside Commitments: (1) are professional and other activities that are related to a University Employee’s professional expertise, outside of their University duties and responsibilities; (2) are for the benefit of an external entity or individual and are not covered by a fully executed written agreement between the University and the external entity; and (3) require a time commitment. Outside Commitments include Outside Employment, independent contracts for consulting services, private consulting groups comprised of University Employees, volunteer/pro bono work, appointments at postsecondary educational institutions, and foreign components, as that term may be updated by the University’s Office for Responsible Outside Interests.

You can also use this decision tree to determine if the activity is an Outside Commitment: Outside Commitment Decision Tree.

COI Disclosure – Foreign Interests

If you do end up receiving a payment of any amount, an in-kind contribution or Other Support, it must be disclosed as a Foreign Interest.

COI Disclosure – Foreign Travel

PHS and Dept of Energy Investigators only: Must disclose any reimbursed or sponsored travel related to your institutional responsibilities, regardless of the amount, unless received from a Federal, state, or local government agency of the United States; a domestic Institution of Higher Education; or a domestic research institute that is affiliated with a domestic Institution of Higher Education.

COI Disclosure – Foreign Affiliations

As part of your eDisclosure submissions, you must disclose whether you have a foreign affiliation.

Financial Conflict of Interest (FCOI) means an Outside Interest is Related to, or can be perceived to be Related to, an individual’s institutional responsibilities.

FCOI determinations answer the question: Could it reasonably appear to someone outside of UA (e.g., front page of the newspaper) that a decision made in the conduct of research was influenced by your Outside Interest?  That influence could affect the design of the project, a decision to exclude data, a decision to delay publication of research results, a decision to overemphasize or underemphasize research results, etc. for the benefit of your Outside Interest.

Related to is a defined term that refers to the condition in which it may reasonably appear that decisions made by the Investigator in the performance of his/her institutional responsibilities could directly and significantly affect the value of his/her Significant Financial Interests or be in conflict with Significant Personal Interests or Foreign Interests.

Relatedness includes situations in which an Investigator’s Outside Interests would reasonably appear to affect, or to be affected by, the individual’s Research or other institutional responsibilities.

Relatedness is not a judgment on whether an Investigator would deliberately make choices in the Conduct of Research or the performance of their Institutional Responsibilities based on considerations related to their Outside Interest. Rather, “Relatedness” refers to the condition in which it may reasonably appear that choices made in the Conduct of Research or other performance of the individual’s institutional responsibilities could be directly and significantly influenced by the existence of an Outside Interest. 

Foreign affiliations are defined as associations/relationships (e.g. conducting activity such as consulting engagements, research collaborations, appointments or titles, or teaching) with foreign institutions of higher education, foreign governments, foreign companies or foreign nationals.

Stock and equity valuation should be updated as follows:

Public Entity: Update at least annually, based on Annual Report or other public valuation

Non-Public Entity:

• If original value is $4,999 or less, update within 30 days of value reaching $5,000 or more

• If original value is $5,000 or more, update at least annually

See Also

• How do I disclose stock or equity?
• How do I value stock and equity?

The value of Equity is determined through reference to public prices or other reasonable measures of fair market value (e.g., assets - liabilities = value).

Stock in a public entity is valued based on Annual Reports and other public valuations.

Valuing stock in a private entity can be done various ways using methods such as valuation ratios, internal rates of return, comparative analysis and discounted cash flow analysis.

See Also

• How do I disclose stock or equity?
• When should I update the value of my stock or equity?

Stock and equity only need to be disclosed if they are an Investigator's Significant Financial Interest or a University Employees Substantial Interest.

A Significant Financial Interest includes:

• Any equity in a private company, regardless of value

• Equity valued at $5,000 or more in a public company

However, income from investment vehicles such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made by the investment managers within these funds or accounts, do not require disclosure.

A Substantial Interest includes:  The ownership of three percent or more of the shares of a corporation for profit, where the total annual income from dividends, including the value of stock dividends, from the corporation exceeds five percent of the total annual income of the employee.

Completing the Stock in External Entity Page in eDisclosure

On the Stock or Equity page in eDisclosure, there are two options for disclosing stock and equity:

1. "Do you own stock / partnership shares in this organization?" should be used to disclose (1) stocks and shares that you own in a public entity and (2) partnership agreements/shares.
2. "Do you own stock options or any other form of equity in this organization?" should be used to disclose (1) other ownership interests (e.g., equity in a private entity), (2) stock options, including Employee Stock Options ("ESOs"), and stock warrants.

Stock & Equity Definitions

• Equity is any stock or other ownership interest, or an entitlement to obtain any stock or ownership interests (e.g., stock options and warrants). The value of Equity is determined through reference to public prices or other reasonable measures of fair market value (e.g., assets - liabilities = value).
• “Exchange-traded funds (ETFs) are SEC-registered investment companies that offer investors a way to pool their money in a fund that invests in stocks, bonds, or other assets. In return, investors receive an interest in the fund.  Most ETFs are professionally managed by SEC-registered investment advisers.  Some ETFs are passively-managed funds that seek to achieve the same return as a particular market index (often called index funds), while others are actively managed funds that buy or sell investments consistent with a stated investment objective.  ETFs are not mutual funds.” (https://www.investor.gov/introduction-investing/investing-basics/glossary/exchange-traded-fund-etf, last visited Oct. 27, 2022)
• “Options are contracts giving the purchaser the right – but not the obligation -- to buy or sell an underlying asset at a fixed price within a specific period of time. Stock options are traded on a number of exchanges.” (https://www.investor.gov/introduction-investing/investing-basics/glossary/options, last visited Oct. 27, 2022)
• Partnership Shares is a partnership arrangement between two or more people to oversee business operations and share its profits and liabilities. (See generally https://www.irs.gov/businesses/partnerships, last visited Oct. 27, 2022)
• “Stocks are a type of security that gives stockholders a share of ownership in a company. Stocks also are called ‘equities.’”  (https://www.investor.gov/introduction-investing/investing-basics/investment-products/stocks, last visited Oct. 27, 2022)
• A Stock Warrant “is a contract that gives the holder the right to purchase from the issuer a certain number of additional shares of common stock in the future at a certain price, often a premium to the stock price at the time the warrant is issued.” (https://www.finra.org/investors/insights/spac-warrants-5-tips, last visited Oct. 27, 2022)

See Also

• How do I value stock and equity?
• When should I update the value of my stock or equity?

If you are an Investigator and receive a travel reimbursement/sponsorship and/or stipend of any amount from a foreign entity, this must be disclosed as a Foreign Interest for conflict of interest review.

If you are an Investigator and receive a stipend of $5,000 or more, this must be disclosed as a Significant Financial Interest for conflict of interest review.

If you are an Investigator who has funding from a PHS agency or the Department of Energy and receive a travel sponsorship or reimbursement of any amount, this must be disclosed as a Significant Financial Interest for conflict of interest review.

If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.

If you are an Investigator, this activity should be disclosed for conflict of interest review if it meets the definition of a Significant Personnel Interest.  Significant Personal Interests are any managerial, professional, or Fiduciary Position you (or a Family Member) hold in any outside entity, whether or not you or your family is compensated. This can include officer, director, and board positions.

Fiduciary Position means one's legal and/or ethical obligation to act in the best interests (e.g., the financial and/or operating success) of another person or entity, regardless of whether such role is compensated. Examples of Fiduciary Positions include but are not limited to membership on a board of directors or board of advisors, or a management role in an entity (e.g., as a corporate officer, LLC member, general partner, and governing board member of a professional association).

If this activity meets the definition of an Outside Commitment, it should be disclosed for conflict of commitment review.  The Outside Commitment Decision Tree on our Disclosure Requirements webpage may be of assistance in making this determination.  Individuals can also contact OROI at coi@arizona.edu.