UCLA Policy 925:	Financial Conflicts of Interest in Research
Issuing Officer:	Vice Chancellor for Research	Printable View
Responsible Dept:	Office of Research Administration
Effective Date:	May 22, 2007
Supersedes:	UCLA Policy 925, dated 6/12/2003

Introduction   |   Background   |   Statement   |   References

I. INTRODUCTION

UCLA is committed to ensuring that research and scholarly activities are carried out under the highest standards of ethical conduct and adhere to Federal and State regulations, and University policies governing the conduct of research. The University’s overall policy on conflict of interest is that none of its faculty, staff, managers or officials shall engage in any activities that place them in a conflict of interest between their official activities and any other interest or obligation. Over the years a variety of specialized policies and guidelines have been issued in recognition of the need for guidance in this area and in related areas of ethical standards and codes of conduct. This policy is specifically focused on the area of financial conflicts of interest in research.

II. BACKGROUND

University of California faculty and staff engage in increasingly complex relationships with outside entities, both for-profit and non-profit. UCLA supports the translation of results from these relationships into practical applications for the public good. To this end, the University supports patenting and licensing activities to ensure that faculty inventions are protected, and to permit faculty to participate in the establishment of industry partnerships designed to commercialize novel technologies, to accept company-sponsored research funding, and to consult for outside organizations.

III. STATEMENT

Faculty and staff relationships with outside entities must support the UCLA mission and its principal objectives of teaching, research and service, but should not create inappropriate external biases affecting the freedom of faculty to pursue all areas of academic inquiry.

A conflict of interest in research may exist when an individual or institution has interests in the outcome of the research that might compromise the integrity of the research. This policy provides the mechanism for the proper review of such interests in order to determine whether a financial conflict of interest exists and, if so, whether action must be taken to eliminate, reduce or manage the conflict before the contract, grant or gift supporting the research may be accepted.

1. In accordance with State of California and Federal regulations, UC policies, and UCLA policies and procedures, certain UCLA employees with responsibility for the design, conduct or reporting of a project funded or supported in whole or in part through a contract or grant, and the recipients of certain gifts, are required to file disclosures of financial interests either in the sponsor of the research or in other organizations to which the research is related before UCLA can accept the research support. The term financial interest as used in this policy includes but is not limited to management positions, income, ownership interests, loans, gifts and intellectual property interests.
   
   
2. Specific thresholds for disclosing financial interests are defined under State of California and Federal regulations and have been incorporated into UCLA procedures for reporting of those interests. The procedures and forms for disclosing financial interests vary depending upon the source of the project funds. For more information, refer to:
   
   

UCLA Procedure 925.1, Disclosing Financial Interests in Non-Governmental Donors of Gifts



UCLA Procedure 925.2, Disclosing Financial Interests in Non-Governmental Sponsors of Contracts and Grants for Research



UCLA Procedure 925.3, Disclosing Financial Interests Relevant to Federally Sponsored Contracts and Grants for Research

Positive disclosures of financial interests are reviewed by the campus Conflict of Interest Review Committee (CIRC), appointed by the Chancellor and advisory to the Vice Chancellor for Research, or by other campus officials designated for this purpose. Upon completion of the review, recommendations are forwarded to the Vice Chancellor for Research who makes the final decision about acceptance of the award.

3. State of California regulations also require that individuals responsible for the review and approval of research conducted under UCLA’s auspices must disqualify themselves from influencing or participating in decisions related to research supported by entities in which they have a personal financial interest. This means that department chairs, deans, and other campus officials must disqualify themselves from approving proposals for projects supported by entities in which they have a financial interest.

IV. REFERENCES

1. UCLA Policy 150, Conflict of Interest;
   
   
2. Memorandum from Vice Provost Robert Shelton, February 4, 1997;
   
   
3. Guidelines for Disclosure and Review of Principal Investigator’s Financial Interest in Private Sponsors of Research, April 27, 1984;
   
   
4. University Policy on Disclosure of Financial Interest in Private Sponsors of Research, April 26, 1984;
   
   
5. University of California Policy on Disclosure of Financial Interests and Management of Conflicts of Interest Related to Sponsored Projects, revised October 15, 1997;
   
   
6. University of California: Political Reform Act Disqualification Requirements, January 2003.
   
   
7. University of California Conflict of Interest Code.