Conflicts of Interest Disclosure

This addresses financial interests that may result in a conflict of interest related to a staff member’s institutional responsibilities that include, but are not limited to research, education, clinical practice, purchasing and administrative activities.

Financial interests include any of the following for the staff member, his/her spouse, domestic partner or dependent children:

•  Holders of equity, including stock, stock options or warrants, in publicly traded or privately held companies (This excludes investments in mutual funds over which staff members have no direct oversight).
• Recipients of consulting income, honoraria, salary (excluding that from UNT Health), gifts or other emoluments or other in-kind compensation per year.
• Recipients of license fees, equity, royalties or contractual rights to receive royalties either through UNT Health or from an external entity.
• Recipients of unrestricted research or education grants.
• Service as an officer, director or in any other fiduciary role for a commercial entity.

Institutional Financial Conflicts of Interest may occur when UNT Health:

• Receives royalties from a technology invented by staff and licensed to a commercial entity.
•  Accepts equity and/or makes a direct investment in a company to which it licenses technology.
• Starts a company based on technology developed at UNT Health.
• Approves participation by its leaders to serve as a member of the board of directors for a commercial entity.
• Enters a joint venture, collaboration or partnership with a commercial entity.

Relationships/activities with entities that relate to UNT Health activities or that conduct business with UNT Health.

Examples of when to disclose: 

• My husband is a sales representative for [company name], which is an approved vendor for UNT Health.
• My partner works for a pharmaceutical company that sponsors research studies at UNT Health.
• My wife is a freelance writer who worked with my department for five years. She still occasionally writes articles for us.
• I am currently a member of the board of directors at [company name], which has a long-term contract to supply UNT Health with goods/services.

Example of when not to disclose: 

• Relationships/interests with entities that have no interaction with UNT Health.

Gifts to UNT Health from suppliers can affect or appear to affect the objectivity of judgment with respect to both the gift giver and recipient.

Explain how you handled the individual gift (e.g., you donated it or returned it) and, who was notified (e.g., your immediate supervisor, Office of Institutional Integrity and Awareness, etc.).

Examples of when to disclose: 

• Gifts that have a more than nominal value (above $50).
• Significant individual gifts, such as holiday hams, steaks, gift certificates over $25, wine, iPads, private air travel, etc.
• Hospitality (outside of an occasional business meal) from a UNT Health vendor).
• Cash or checks from individuals internal or external to UNT Health.
• Gifts provided to UNT Health vendors or suppliers (e.g., providing a vendor tickets to a UNT Health sporting event).

Example of when not to disclose: 

• Promotional items, occasional business meals, or nominal gifts (e.g., flowers, baked goods, candy, pens, notebooks, etc. Note: Gifts to a department or team should be placed in a common area to be shared, such as a department kitchen or conference room.
• Charitable or other donations that you or a family member may have contributed to UNT Health or a company that does business with UNT Health.

For gifts greater than incidental use of UNT Health time or resources for outside activities, disclosure examples would be:

• “I am involved in civic activities for which I use my work computer to make meeting materials and receive e-mails. I occasionally receive and make related phone calls, too.”
• “I occasionally use the department copier to make handouts for a youth group I volunteer with once a month. I have discussed this with my supervisor. “