Outside Interests: Significant Financial, Personal and Foreign Interests

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.

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

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.

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:

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, 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.

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 entit

Overlap between an Outside Interest and a Research Project occurs when there is Relatedness.

“Relatedness” is 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.

A foreign entity is: