The University of California, Santa Cruz, has high standards for Faculty conduct, including the conduct of research, as discussed in the University of California Faculty Handbook and the Academic Personnel Policy Manual. All UCSC Investigators are expected to carry out research consistent with these standards.

Even when these high standards have been met, however, conflicts of interest or perceptions of conflicts may still occur when there is a convergence of an Investigator's private interests with his or her research interests, such that an independent observer might reasonably question whether the Investigator's professional actions or decisions are improperly influenced by considerations of personal financial gain. Such conflicts are common in modern research universities and do not necessarily impugn the character or actions of any individual.

Although the University does not require Investigators to disclose their personal financial interests as a matter of routine, the University is sometimes obligated by external requirements to require disclosure processes. Such disclosure processes are the most widely accepted method for identifying and managing actual or potential conflicts of interest related to sponsored projects in public institutions.

It is the policy of the UCSC that any Investigator (that is, any University employee responsible for the design, conduct, or reporting of a sponsored project at the University) that is proposing a sponsored project with funding from NSF, PHS (Including NIH) or a private (profit or non-profit) agency, is required to submit a disclosure of interests. When the University determines that such an interest might reasonably appear to be directly and significantly affected by the sponsored project, the University will take steps either to manage or to eliminate the conflict.

Forms:
Disclosure of Financial Interest for NSF and NIH (65K)
Statement of Economic Interests in a non-governmental sponsor (700-U)

STATE & FEDERAL DISCLOSURE REQUIREMENTS

Federal Requirement to Disclose Significant Financial Interest

The National Science Foundation (NSF) and the Public Health Service (PHS) require disclosure of significant financial interests by investigators receiving support for research and other sponsored activities from those sponsors either directly or via subaward. The American Cancer Society, American Heart Association, UC Discovery Grants, UCOP Special Research Programs, California Institute for Regenerative Medicine, and International Vaccine Institute have also adopted the federal requirements.

What is filed: Each member of the research team who has a disclosable interest must complete the Disclosure of Financial Interests Form.

Who Files: All Principal Investigators, Project Directors, Co-Principal Investigators, and any other members of the research team (e.g., post-docs) who will be responsible for the design, conduct, or reporting of the proposed project.

What is disclosed: All financial interests of the responsible individual, spouse, and dependent children exceeding $10,000 or 5% ownership in entities that might be affected by the research being conducted on the proposed project. Financial interest means anything of monetary value, including salary or other payments for services (from any sources other than UC), equity interests, and intellectual property rights (patents, copyrights, and royalties from such rights.)

State of California Requirement to Disclose Financial Interest

The State of California requires disclosure of financial interest(s) when a research project is funded or supported in whole or in part by a gift, grant, contract, or (under certain circumstances) Material Transfer Agreement (MTA) from a non-governmental organization (NGO).

Note: Funding from certain NGOs will not trigger a 700-U disclosure as they have been exempted from the process by the State. A list of those NGOs is found at http://www.ucop.edu/research/exempt.html.

Who Files: All persons employed by UC who have principal responsibility for a research project as defined by the State. The individual filer is responsible for certifying under penalty of perjury as to the correctness and veracity of the information in the disclosure.

What is filed: A 700-U Statement of Economic Interests for Principal Investigators and, if a defined financial relationship is disclosed, a 700-U Addendum.

What is disclosed: 1) paid or unpaid positions, including but not limited to, consultant, trustee, or director; 2) equity interest or investment(s), whether direct, indirect, or beneficial; 3) aggregate income of $500 or more within the last 12 months, where income includes but is not limited to salary, interest, royalty payments, proceeds from sale, gifts, reimbursement for expenses, per diem; 4) loans within the last 12 months where the amount oewed was at least $500; 5) certain travel payments; gifts of $50 or more.