Approving Authority: For purposes of receiving and reviewing Conflict of Interest disclosures and Outside Activities, Approving Authorities include:

- For OHSU faculty: Department Chair or Institute Director;

- For Department Chairs or Institute Directors: Dean or Senior Vice President;

- For other OHSU employees: Immediate supervisor.

Conflict of Commitment: A Conflict of Commitment occurs when the time, the nature of the activity, or the use of OHSU resources in external activities interferes with, compromises, or diminishes the individual's capacity to meet his or her OHSU responsibilities.

Conflicts of Interest: A Conflict of Interest (CoI) exists when an OHSU Member's financial interests or other obligations interfere, or appear to interfere, with the Member's obligations to act in the best interest of OHSU and its missions, and without improper bias.

Conflict of Interest in Research: A determination by the designated official that a Significant Financial Interest (SFI) might affect, or reasonably appear to affect, the design, conduct, or reporting of research.

Designated Official: For the purpose of Conflict of Interest in Research disclosures as required under Public Health Service (PHS) regulations, the Senior Vice President for Research or individual(s) appointed by the Senior Vice President for Research.

Executive Position: Any position which includes responsibilities for a material segment of the operation or management of a business. This would include a position on a Board of Directors.

Gift: Something of economic value given by a business or individual that does or may seek to do business with OHSU to an

OHSU Member for which the OHSU Member makes no payment or makes payment at a discounted price. Examples include but are not limited to notepads, pens, coffee mugs, clocks, or similar items;travel;tickets to sporting or other events;complementary registration to educational or scientific events;food and beverages, but excludes (i) items where the same Gift offer is made or available to the general public on the same terms and conditions, and (ii) those items excluded from the definition of gift as set forth in the Section E of this policy.

Institutional Conflict of Interest: An Institutional Conflict of Interest may exist when an OHSU Executive, or OHSU, has a Significant Financial Interest in a company or organization that currently does business with or is seeking to do business with OHSU, and those interests may interfere, or appear to interfere, with the obligation to act in OHSU or the public's best interest.

Institutional Gift: Donations of financial value, including gifts in kind, provided to OHSU or any of its sub-parts. Such gifts include monetary funds, scholarships, sponsorship of educational events, textbooks, subscriptions, equipment, devices, and similar gifts of value.

Institutional Responsibilities: An individual's professional responsibilities on behalf of OHSU, which include, but are not limited to, activities such as research, teaching, clinical care, business transactions, committee memberships, and service on panels such as Institutional Review Boards or Data and Safety Monitoring Boards.

Institutional Significant Financial Interest: (1) Institutional Significant Financial Interests include:

(a) Intellectual property rights: e.g., patents, copyrights and royalty income or the right to receive future royalties under a patent license or copyright;(b) Equity interest or entitlement to equity of any amount in a non-publicly traded company;(c) Equity interest or entitlement to equity greater than $100,000 in a publicly traded company;(d) Receipt of gifts from any entity with which OHSU places business that in total over one calendar year exceeds $100,000.

Investigator: The principal investigator, co-investigator and other OHSU employees or volunteers, or any OHSU research collaborator, including visiting scientists or consultants, responsible for the design, conduct or reporting of research or educational activities or responsible for preparing a proposal for research funding.

Household Member: Any person who resides with the OHSU Member.

Legitimate Academic Conference: A conference that is typically publicized in advance with a planned agenda/program, is open to the appropriate professional group or the public (rather than by invitation only) and would include printed or electronic materials for attendees.

OHSU Executive: OHSU Board of Directors members, the President, Vice Presidents, Deans, and all who report directly to a Vice President or Dean, except administration support personnel.

Outside Activity: An activity conducted by an OHSU member that a) falls "outside" of the requirements or scope of the individual's employment or position at OHSU and that b) utilizes skills, expertise and/or education that are similar but not necessarily identical to those for which he/she is employed or engaged at OHSU and/or that is conducted with the use of OHSU space, facilities or support, except to the extent that incidental use is specifically permitted by OHSU policies.

Examples of Outside Activities include but are not limited to paid or unpaid activities such as consulting agreements;contract appointments to serve as "on call" expert witness;memberships of scientific advisory boards;positions at another entity (e.g., as employee, board member or officer). (a) Exceptions to advanced reporting of certain Outside Activities: Some Outside Activities do not require advance reporting if the associated income or other financial interests involved do not meet the threshold for a Significant Financial Interest as defined below.

(i) Activities that do not require any reporting as Outside Activities include:

1. Unpaid professional activities that do not include serving as an officer or Executive Position of the external entity;

2. Occasional service for governmental or not-for-profit organizations such as scientific and technical groups, commissions and professional organizations that involve no more than modest reimbursement for service related expenses.

(ii) Activities that require reporting only retrospectively with the annual Conflict of Interest disclosure include the following:

1. Occasional lecture or seminar participation that involves no more than modest reimbursement for service related expenses.

2. Published scholarly work that results in royalties and that was developed using minimal institution resources.

3. Occasional expert witness testimony.

Purchasing Committee: Any OHSU committee formed to review a potential purchase (e.g., value analysis committees, capital committee, RFP committees).

Relative: The spouse, registered domestic partner, domestic partner of the OHSU Member or the children (including adult children), siblings, spouses of siblings, or parents or step-parents of the OHSU Member,

Research: A systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge. As used in OHSU policies, the term "research" encompasses basic and applied research and product development.

Significant Financial Interest: Includes the following interests of the discloser (and those of the discloser's spouse or registered domestic partner and dependent children):

1) Compensation: i.e., anything of monetary value including, but not limited to, salary, gifts, consulting fees, honoraria or other payments for services that is more than five thousand US dollars ($5,000) in the aggregate over the last twelve (12) months;

2) Equity interests: e.g. stocks, stock options, warrants, contractual rights to acquire or receive ownership interests, or other ownership interests in a publicly-traded company that is more than five thousand US dollars ($5,000) or any amount in a non-publicly-traded company;

3) With respect to a publicly-traded company, the aggregated value of compensation over the last twelve (12) months and equity interest that is more than five thousand US dollars ($5,000);

4) Intellectual property rights: e.g. patents, copyrights and royalty income or the right to receive future royalties under a patent license or copyright;

5) Non-royalty payments or entitlements to payments in connection with the research that are not directly related to the reasonable costs of the research (e.g. bonus or milestone payments to the investigators in excess of reasonable costs incurred);

6) Service as an officer, director, or in any other Executive Position in an outside business, whether or not remuneration is received for such service;and

7) Reimbursed or sponsored travel (applies to investigators involved in PHS funded research only and not their spouse, registered domestic partner or dependent children). Disclosures shall include the purpose of the travel, the identity of the sponsor/organizer, the destination and the duration of the travel, and any other information as requested by the disclosure form or designated official. See exemptions in (6) below.

Exceptions: Significant Financial Interests do not include the following:

(1) Interests of any amount in publicly traded, diversified mutual funds or retirement accounts so long as the OHSU Member does not directly control the investment decisions made in these vehicles.

(2) Payments to the institution, or via the institution to the individual, that are directly related to reasonable costs incurred in the conduct of research as specified in the research agreement(s) between the sponsor and the institution.

(3) Salary and other remuneration from OHSU, including approved faculty practice plan earnings and the distribution of those earnings that may be established by departmental or other similar agreements provided that those agreements and departmental/divisional group plans are approved by the President.

(4) Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education;or

(5) Income from service on advisory committees or review panels for a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.

(6) Reimbursed or sponsored travel that is reimbursed or sponsored by a federal, state or local government agency, an Institution of higher education, an academic teaching hospital, or a research institute that is affiliated with an Institution of higher education.

Vendor: any outside entity or company in the business of supplying products, devices, equipment, and/or services that may be purchased for use by OHSU (e.g., in performing clinical, research, education, or administrative operations).