Conflicts of Interest

Financial Interests to Disclose

Original Effective Date 09/30/2003
Last Revised Date 05/25/2022

All personal financial interests, and those of the individual’s spouse and dependent child(ren), that appear to be related to a covered individual’s institutional responsibilities at WashU must be reported, regardless of value. Institutional responsibilities are defined as an individual’s professional duties and responsibilities on behalf of the University. These may include, but are not limited to activities such as research or other scholarly inquiry, education, professional practices, clinical activities, administration, institutional committee membership, and service on panels such as internal review boards and data and safety monitoring boards. Examples of financial interests:

Required to be disclosed Not required to be disclosed
Compensatio​n for Any Remuneration regardless of value including but not limited to:

  • Consulting activities
  • Service on an advisory board or board of directors
  • Product evaluation payments
  • Legal consulting activities (such as expert witness testimony)
  • Service to a non-profit organization (such as service on a board or consulting)
  • Employment (other than WU)
  • Publishing agreements,
  • Royalties for books, or
  • Authorship
  • Honoraria or other compensation for activities such as talks or educational activities
  • Salary or other remuneration paid by WashU
  • Service on advisory committees or rev​iew panels paid for by U.S. government agencies
  • Income from travel, seminars, lectures, or teaching engagements sponsored by:
    • U.S. federal, state, or local government agency, or
    • U.S. institutions ​of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education​

  • Receipt of any income related to intellectual property rights (e.g. cash royalty payments), and includes:
    • Royalties from other academic institutions
    • Royalties paid through WashU for  intellectual property rights assigned to WashU
  • An agreement with an entity, including WashU, that entitles an individual to future royalties but no income has been received
  • Invention disclosures or patents
Equity/ Ownership Interests
  • Ownership interest in an entity (stocks, stock options, warrants, or other ownership interest)
  • Income from investment vehicles (such as mutual funds, retirement accounts, and blind trusts) as long as the individual does not have direct control over the investment decisions
Travel Only applicable to investigators funded by sponsors that follow PHS or similar disclosure rules (e.g. PHS, DOE, AHA):

  • Travel for which the individual is either reimbursed for or paid for on the individual’s behalf and includes registration fees, accommodation, transportation costs, etc.
Travel paid for by:

  • WashU
  • U.S. federal, state, or local  government agencies
  • Other U.S. institutions of higher education, academic teaching hospitals, medical centers, or research institutes affiliated with an institution of higher education
  • Gifts or other personal financial benefit