手册

I.政策和一般性声明

The University of Texas Health Science Center at Houston (“university”) has an obligation to conduct its activities with utmost integrity. At times, the university and its employees must balance competing interests. Academic-industry relationships are important to advancing scientific frontiers and are essential to enabling commercial development of academic and research discoveries for the benefit of the public. These relationships may lead to financial benefit to institutions. Institutional conflicts of interest ("Institutional COI") may involve financial interests of institutional officials or the university itself. Such conflicts of interests should be properly identified and managed so they do not compromise or appear to compromise the primary mission of the university in patient care, research and education.See箍94，研究冲突beplay苹果手机能用吗, for additional information about institutional conflicts of interest related to research.

该政策旨在通过提供大学官员和大学财务利益的批准，披露和文件的透明批准，披露和记录，以保护大学，UT系统和大学员工的信誉和声誉，这可能引起人们对冲突的担忧兴趣。

不得允许该机构或机构官员的外部财务利益破坏研究，教育，临床护理或其在大学的管理中的客观性或活动。beplay苹果手机能用吗大学必须披露和管理任何妥协或似乎损害其完整性或任务的关系。一个中心原则是，应尽可能避免或消除大学或其官员的利益冲突。但是，如果令人信服的环境证明具有固有利益冲突的活动是合理的，则必须制定，批准，实施和监控全面的管理计划（“计划”）。

ii。定义

家庭成员：

• A spouse;
• a dependent child or stepchild or other dependent (for purposes of determining federal income tax liability during the period covered by the disclosure statement); and
• a related or non-related, unmarried adult who a) resides in the same household as the individual and b) with whom the individual is financially interdependent as evidenced, for example, by the maintenance of a joint bank account, mortgage, or investments.

Institutional Conflict of Interest:An Institutional COI describes a situation in which the financial interests of the university or of a Level I or Level II institutional official (see below), acting within his or her authority on behalf of the institution, poses or may pose a risk of undue influence on decisions that affect the research, education, clinical care, business transactions, or other activities of the institution.

Institutional Officials:任何雇员或其他人员的权威to make decisions to commit resources of the institution.

Level I Institutional Official: The President of the university.

Level II Institutional Officials: Executive Vice Presidents, Vice Presidents, Associate Vice Presidents and Assistant Vice Presidents; Deans, Vice Deans, Associate and Assistant Deans; Department Chairs and Directors of institutes or centers; Directors of organized business or research units (e.g., procurement, sponsored projects, compliance, asset management, business affairs); all licensing, marketing and commercialization professionals in the institution’s technology commercialization office who have the authority to bind the institution; and any other person designated by the President as an institutional official for the purposes of this policy.

Significant Outside Financial Interests of the University (not related to research):大学的大量外部财务利益发生，但不限于该机构收到以下情况的情况：

1. Cumulative gifts from any person, business or entity within the past 10 years of
   1. $1,000,000 or more to the university, or
   2. $100,000 or more to an institutional department, or
   3. $5,000 or more to an individual to conduct research.
2. Payments from a person, business or entity for the licensing of intellectual property that, in aggregate, exceed $250,000 per calendar year.
3. Equity or ownership interests in entities held by the institution, including equity and ownership interests resulting from institutional technology transfer activities, where:
   1. 在公开交易实体的情况下，这种股权或所有权权益的价值超过100万美元，或
   2. 该机构在非公开交易实体中具有任何所有权权益，该实体的资本化超过100万美元。

These situations will be reviewed to ensure appropriate management of相关大学business decisions.

Significant Outside Financial Interests of an Institutional Official (not related to research): Significant outside financial interests of an institutional official occur, but are not limited to circumstances where the institutional official has the following:

1. 对企业的重大兴趣：
   1. 控制兴趣；
   2. 拥有超过1％的投票权益的所有权；
   3. Ownership of more than $5,000 of the fair market value;
   4. A direct or indirect participating interest by shares, stock or otherwise, regardless of whether voting rights are included, in more than 1% of the profits, proceeds or capital gains; and/or
   5. Service as an officer.
2. 礼物超过250美元，在12个月内赠送给机构官员或他/她的直系亲属。不包括收到的礼物：父母，孩子，兄弟姐妹，祖父母或孙子，是上述任何人的雇员和配偶的配偶；
3. 外部活动可能会合理地影响或影响大学的活动或任务或以其他方式影响机构的利益冲突；和/或
4. 机构官员的直系亲属的任何活动或企业实体中直接家庭成员的任何重大利益，可能会对机构的活动或任务产生合理影响或影响或影响或影响。

III. PROCEDURE

A. Disclosure of Financial Interests

Disclosures of financial interests of institutional officials are addressed inHOOP 20, Conflict of Interest, Conflict of Commitment and Outside Activities。大学本身的财务利益将由利益冲突办公室每年获得：

1. 技术管理办公室：大学持有的技术商业化或技术转让活动和所有权利益的许可收入（特许权使用费和/或权益）；
2. 开发办公室：该机构收到的捐助者的礼物/赠款；
3. Sponsored Projects Administration: Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) grants where there is an Institutional COI; and
4. 任何其他适当的来源。

B. Institutional Conflicts of Interest Committee

The Office of the Executive Vice President & Chief Academic Officer shall maintain an Institutional Conflicts of Interest Committee (ICOIC) established by the Executive Compliance Committee (ECC). The Committee shall be appointed and charged and operate according tobylawscreated by the ECC.

The purpose of the ICOIC is to provide advice, guidance and recommendations to the President, the Chief Compliance Officer (CCO), the Executive Compliance Committee (ECC), the Executive Vice President & Chief Academic Officer ("EVP/CAO"), the Senior Executive Vice-President, Chief Operating/Chief Financial Officer (COO/CFO), and The University of Texas System Executive Vice Chancellor for Health Affairs (EVC) regarding real, perceived, and potential conflicts of interest of the University and its officials. For purposes of this policy, specific responsibilities of the ICOIC include the following:

1. 由于大学的财务利益及其机构官员的身份，建立了确定真实，感知和潜在的机构COI的机制，这些机制对大学的决定，职能和行动构成了不当影响的机构官员；和
2. Reviewing the financial interests of the university, its institutional officials, and other employees to identify real, perceived, or potential institutional and individual conflicts of interest (HOOP 20, Conflict of Interest, Conflict of Commitment and Outside Activities).
   1. 如果委员会认为冲突可以管理d to prevent undue influence on the university's decisions, functions, or actions, or those of an employee(s), it shall recommend a Plan that must be approved by the EVP/CAO and the COO/CFO. Any Plans involving the EVP/CAO or the COO/CFO must be approved by the President.
   2. If the Committee believes a conflict cannot be eliminated or managed so as to prevent undue influence on the university's decisions, functions, and actions, or those of an employee(s), it shall recommend to the ECC actions to remove the conflict. If the ECC concurs, it will forward the recommendation to the President for a final decision and implementation.
3. Providing additional information, guidance, and recommendations to the President, CCO, ECC, EVP/CAO, COO/CFO, and EVC upon request.

Any member of the ICOIC who has a financial interest in or serves as a paid consultant for an entity shall not participate in the review of the Institutional COI issues related to that entity under this policy.

C. Management of Institutional Conflicts of Interest

A central principle is that conflicts of interest of the institution or of an institutional official(s) should be avoided or eliminated where possible. However, if compelling circumstances justify an activity with inherent conflicts of interest, a comprehensive Plan must be developed approved, implemented, and monitored. The purpose of each Plan is to minimize the likelihood that the Institutional COI will pose risks of undue influence on decisions involving institutional officials, primary interests, or key missions.

Institutional COIs involving the university’s financial interests and those of its Level II institutional officials will be managed by the ECC upon the recommendation of the ICOIC. The ICOIC will identify real, perceived, or potential conflicts of interest of the university and its Level II institutional officials based upon review of their required financial disclosures, their approved outside activities and any associated financial relationships, and any other disclosures or reports required by this policy. Based upon its review of these materials, the ICOIC will recommend elimination or management of the conflict.

当机构COI与拟议或正在进行的研究相关时，ICOIC将与研究冲突（RCOI）委员会合作管理机构COIbeplay苹果手机能用吗(箍94，研究冲突beplay苹果手机能用吗)。

Some of the possible management strategies include, but are not limited to:

• Eliminate the financial interest (e.g., divestiture) or reduction to a level below the minimum threshold;
• Recuse an institutional official from decision making or participation in an activity that would directly or indirectly involve the person’s financial interest;
• Place the conflict-causing economic interests (e.g., stocks, options, bonds) in a blind or double-blind trust;
• Require oversight of decision-making or participation in an activity by an independent third party;
• Recuse an institutional official from participation in negotiations involving a financial transaction or licensing agreement between the affected institution and the relevant entity;
• Recuse an institutional official from approval of extramural time off for any individual related to the relevant entity;
• Alter the reporting structure when a Level II institutional official having a financial interest with a specific entity directly supervises someone who also has a relationship with the same entity (including, but not limited, to sponsored research); and/or
• Obtain outside IRB review or independent monitoring for human subjects research that is related to the university’s financial interest.

1. I级机构官员

The EVC, or designee, holds the authority to review compelling circumstances regarding any conflicts and to identify, create and approve plans for managing, reducing, or eliminating Institutional COIs involving the President. The EVC will make a final decision and issue directives to the ICOIC for handling, processing, and oversight of compliance as needed, as well as any subsequent information or reports he/she requests.

2. II级机构官员

If management is recommended, the ICOIC will develop a Plan after consultation with the Level II Institutional Official. Plans must initially be approved by the EVP/CAO and COO/CFO. After approval, the EVP/CAO will forward the recommended Plan to the President. The President, or designee, holds the final authority within the institution to review compelling circumstances regarding conflicts and to approve Plans for managing, reducing or eliminating real, potential, or perceived conflicts of interest involving Level II Institutional Officials. At his/her discretion, the President may consult with the Level II Institutional Official and/or others prior to making a final institutional-level decision.

3. Institutional Interests

对涉及大学金融的实例interests, the authority to reject, modify or approve Plans lies with the EVC. The ICOIC shall identify potential conflicts of interest involving the university’s financial interests and shall review, recommend elimination and/or management of the institutional conflicts of interest, inform the President of its recommendations and provide an opportunity for the President to make comments.

The ICOIC shall review Plans annually to determine if the Institutional COI persists, document compliance with previous Plans and assess the need for reissuing or modifying the Plan.

The ICOIC is also responsible for periodically reviewing conflict of interest policies and procedures and recommending changes as required.

D.违规

Failure to comply with any portion of this policy, applicable federal regulations, state laws, rules and regulations of The University of Texas Board of Regents, UT System policies, university policies, and/or the terms of an approved Plan may result in the total withdrawal of, or limitations to, the university’s approval of institutional officials’ outside activities. Further, such failure may result in disciplinary action, up to and including termination of employment. Civil and criminal penalties may also apply under certain circumstances.

员工应向其直接主管或执行副总裁兼首席学术官办公室报告任何可疑的违规行为。员工还可以匿名向涉嫌违法行为报告合规热线。In accordance with箍，108保护免于报复, retaliation for a good-faith report of suspected violations will not be tolerated. Detailed information on reporting possible violations may be found in the university’sStandards of Conduct Guide。

E. Training

All employees are required to undergo mandatory compliance training, which includes training on conflicts of interest. For further explanation and guidance regarding this policy, refer to theConflicts of Interest Guidelinesor to theStandards of Conduct Guide或联系Office of Executive Vice President & Chief Academic Officer。

IV. CONTACTS

• • Office of the Executive Vice President & Chief Academic Officer - Conflict of Interest Office
  • 713-500-3214
  • coi@uth.tmc.edu
  • https://inside.uth.edu/evpara/coi/index.htm

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