Step 2: Ethics and Conflicts of Interests
Ethical Values & Conduct
Values
Members of the University of California community are committed to the highest ethical standards in furtherance of our mission of teaching, research and public service. We recognize that we hold the University in trust for the people of the State of California. Our policies, procedures, and standards provide guidance for application of the ethical values stated below in our daily life and work as members of this community.
We are committed to:
- Integrity: We will conduct ourselves with integrity in our dealings with and on behalf of the University.
- Excellence: We will conscientiously strive for excellence in our work.
- Accountability: We will be accountable as individuals and as members of this community for our ethical conduct and for compliance with applicable laws and University policies and directives.
- Respect: We will respect the rights and dignity of others.
Additional reading: Statement of Ethical Values
Conduct
All members of the University community, including The Regents, Officers of The Regents, faculty and other academic personnel, staff, students, volunteers, contractors, agents and others associated with the University are expected to abide by these Standards of Ethical Conduct:
Additional Reading: Standards of Ethical Conduct
Reporting Improper Activities
UC Whistleblower Hotline (anonymous/confidential)
(800) 403-4744 or http://universityofcalifornia.edu/hotline
Please visit the ANR Whisleblower page to learn more.
What is a Conflict of Interest
What is a Conflict of Interest?
A conflict of interest occurs when an individual or organization has an interest that might compromise the objectivity of the research. The majority of the University’s research funding comes from public sources, such as the federal government. With this support comes public scrutiny about research methods and results. In addition, private industry also funds research at the University of California. While this support can provide resources that would not otherwise be available, industry funding and the often complex relationships between industry and researchers have raised public concerns about the trustworthiness of the data that result from such relationships.
Researchers may have many different interests that motivate them to perform their work, including:
These interests are all legitimate incentives to perform research; however they can and often do create a perceived or actual conflict of interest.
A conflict of interest occurs when an individual or organization has an interest that might compromise the objectivity of the research.
Types of Conflict of Interest
Financial Gain:Financial conflicts of interest are situations that create perceived or actual tensions between personal financial gain or loss and adherence to the fundamental values of honesty, accuracy, and objectivity.
Researchers are permitted to benefit financially from their work. However, financial conflicts of interest can lead to the perception that these interests could affect research outcomes.
The University is required to:
Impartial Reviewer: Public and private sponsors of research often will not allow one University faculty member to review the work of another. Therefore, it is important to ask about a sponsor’s conflict of interest rules before beginning to perform such reviews.
Federal Law
Significant financial interests are defined under federal law to be anything of monetary value above a certain threshold in a company or entity engaged in work that appears reasonably related to the research. These include:
Financial Interests | not exceeding | examples |
salary or payments | $10,000 | stocks, stock options |
an equity interest | $10,000 in fair market value or ownership greater than 5% in a single entity |
|
intellectual property rights | N/A | patents, copyrights or royalties |
a management position | N/A | board member, director, officer, partner, or trustee |
California Law
“Financial interest” has a different meaning under California law than it does under federal law. In most cases, California law is more stringent than federal law. The following interests are covered under the California definitions and must be disclosed on behalf of self, spouse or registered domestic partner, and dependent children when they involve the entity sponsoring the research.
Financial Interest | which exceeds | examples |
Income | $500 | salary, wages, honoraria, consulting fees, expert witness fees, advances, proceeds from sale, or loan |
Investment | $50 | any financial interest in a business entity |
Gift | anything of value for which the researcher has not provided equal or greater consideration to the donor | |
Travel Payment | lodging, meals, aifare | |
Management | board member, consultant, member of scientific advisory board, director, officer, partner, or trustee |
Examples
Conflict of Interest | Not a Conflict of Interest |
Funds provided by sponsoring organization and earmarked specifically for researcher | Income received from a UC department by way of a sponsoring organization. As long as the UC department has autonomy on who and how to distribute funds |
Managing Conflict of Interest
If a researcher has a financial interest that is required to be disclosed under federal or state rules, the interest must be reported to the location’s Conflict of Interest committee. Either Manage or Eliminate
COI Management Strategies
COI Elimination Strategies
Importance to Research
A fundamental tenet of research integrity is that the methods used and the reporting of results are objective and free from bias. Thus, researchers should always be willing to voluntarily disclose interests that could give rise to potential conflicts as a way of protecting the integrity of their work. By so doing, researchers will be able to maintain public trust in their own work and in the work of the University
Researchers must be free to pursue knowledge and that this freedom, which is essential to the research process, must not lightly be abridged.When a researcher has a financial interest similar in nature to those required to be reported under the University Conflict of Interest Code requiring disclosure, his or her judgment may appear to be affected by potential financial gain rather than by the pursuit of knowledge. |
Disclosing Conflicts of Interest
Form 800 (For Projects Involving Human Subjects and/or Federal Non-PHS Funded)
The Form 800 is to be completed if your project involves Human Subjects research or is funded by non-PHS Federal agencies, CIRM, UC Discovery or a UCOP Special Program. In accordance with the University of California Policy on Disclosure of Financial Interests, the Principal Investigator and all other UC ANR investigators (all persons who have responsibility for the design, conduct or reporting of research) must disclose their personal and family member’s significant financial interests. The Form 800 must accompany the proposal and be submitted to the Office of Contracts and Grants.
Form 700-U (State of California Disclosure)
Non-exempt, Non-governmental organizations
State of California law requires disclosure of financial interest in the sponsor of a research project when that sponsor is a non-governmental source. The Form 700-U is required to be completed by the Principal Investigator within 3 months prior to the acceptance of an award. Per the State of California original signatures are required on the Form 700u and the original copy must be received by the Office of Contracts and grants prior to acceptance of the award.
Please see also the List of Non-governmental Entities Exempt From Disclosure Requirement.
PHS COI (Federal Public Health Service (PHS) FCOI Regulations)
Please see the Office of Contracts and Grants Website Conflict of Interest Page for more detailed information on this subject.
Disclosure Requirements:
The Public Health Service (PHS) requires disclosure of significant financial interests by Investigators who participate in PHS-funded research either directly or via subaward. Other foundations and agencies have also adopted the PHS requirements which can be found here. “Investigators” are defined by PHS to include principal investigators and any other individual who, regardless of title or position, who has responsibility for the design, conduct, or reporting of such covered research.
- Forms to be submitted at the time of proposal to OCG:
1) PHS COI Form 1
2) PHS COI: Principal Investigator Certification form
3) PHS COI Training and Training Certificate form (see notes regarding training requirement below.
Training Requirements:
All Investigators are required to take PHS-compliant training prior to engaging in PHS-funded research for new awards, whether receiving remuneration or not, and at least every four years while engaging in PHS-funded research.
- UC Compliance and Conflict of Interest for Researchers (COIR) (to be completed through the UCD Learning Management System)
The OCG will review all disclosure forms and refer all positive disclosures to the ANR Conflict of Interest Committee whose charge is to work with the PI to establish a plan to manage the conflict. Approval from the ANR COI Committee is required prior to accepting an award (or work commencing).
Contacts
Questions about conflict of interest may be directed to:
Director, Office of Contracts & Grants
Additional Resources
PHS or NSF Funded? Contact the Office of Grants to instructions on how to take the Conflict of Interest training for Researchers mandated by the University of California for these specific sponsors.