Financial Interests or Relationships That Pose Conflicts of Interest

While most disclosures of financial interests will probably be deemed de minimus or not significant conflicts of interest, financial interests above certain thresholds will automatically be deemed significant conflicts of interest and will require closer scrutiny and possible elimination, mitigation, and/or management.  The thresholds are as follows:

 A.  These interests are over $10,000 in monetary value.

 B. (1) These interests involve the ownership or promise of stock or stock options over $10,000 or 0.5% of the total value of the company, in a publicly traded company.

      (2).  These interests involve the ownership or promise of stock or stock options of any amount in a privately-held or start-up company.

C. An individual serves in a consulting or other fiduciary role for a financially interested company, whether or not remuneration is received.

Research involving human subjects will require that all conflicted investigators provide compelling reasons justifying their involvement in the research despite their conflict, if their financial interests are above the thresholds described in this document.  A simple statement of an investigator's importance or expertise will not suffice.  An investigator with a significant financial stake in the outcome of the research would need to provide a sufficient reason detailing his/her unique contribution to the study, and a reasonable plan that will protect the human subjects, the data, and the university.  Without compelling reasons and a plan that isolates the investigator from direct interaction with the human subjects or identified specimens, the COIC may require that the investigator either divest his/her financial interest or not perform the work at Stanford.

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