Conflict of Interest: Examples and Exceptions

• You own more than $5,000 worth of stock in a publicly traded entity that is related to your area of expertise (e.g., you own stock in Apple and are a faculty member in Computer Science; you own stock in Exxon and your research is in the field of Mineral Engineering, etc.). The equity interest should be disclosed on page 1 in COINS. If it is not related to what you do at Penn State, do not disclose it.
• You are a College of Medicine Investigator and own $1,000 worth of stock shares in a publicly-traded pharmaceutical company. You will participate in a human subjects study sponsored by this pharmaceutical company. The equity interest and related research must be disclosed in COINS.

• You are an Investigator on a human subjects study sponsored by a publicly-traded entity. Your 401(k) retirement account include mutual fund holdings in the publicly-traded entity. As you do not directly control the investment, you are not required to disclose this in COINS.
• You are an Investigator on a human subjects study sponsored by a publicly-traded entity. Part of your salary is supported by the study budget. Because you receive the funds as part of your salary paid by the University, you are not required to disclose this in COINS.

• You are in the process of forming a start-up company. Even if the company does not currently offer any products or services, the equity interest should be disclosed on page 2 in COINS.
• You have a joint appointment with a foreign university, which is a non-profit entity. Any income over $5,000 from a foreign university/non-profit should be disclosed on page 2 in COINS.

• You receive teaching income from a Missouri-based university. Any income received from a United States institution of higher education for seminars, lectures, or teaching engagements is NOT required to be disclosed in COINS.
• You and your spouse form a real estate business. The business does not relate in any way to your responsibilities at Penn State. You are not required to disclose this in COINS.

Anyone who owns any equity in a private company must disclose the names of the other investors whether individuals, banks, or venture capital firms.

• You have started a company that is related to your institutional responsibilities. Several private investors have provided financial backing in exchange for ownership equity in the company. You must disclose the names of the individuals on the Identify the Equity Interests page in COINS.
• You are in a partnership in a company that is related to your institutional responsibilities. The company has been operating for several years and is growing rapidly. The company has secured a bank loan to fund expansion costs. You must disclose the name of the bank and the names of the other individuals who hold equity in the company on the Identify the Equity Interests page in COINS.
• You just started a company that is related to your institutional responsibilities and are the sole proprietor. Several family members have committed to providing private financing. Even though financing has yet to be provided, you must disclose the names of the individuals on the Identify the Equity Interests page in COINS.

• You obtain a patent after the University declined to pursue a patent for an invention you created during the course of your employment. You license this technology to a company. If the licensing fees exceed $5,000, you must disclose this on page 3 in COINS.
• You are a College of Medicine Investigator holding a patent on a new technology that has not yet generated any income (from PSRF or an outside entity) AND you currently participate in a human subjects study related to the technology. This should be disclosed on page 3 in COINS.
• You are an Investigator and you received $16,500 last year in royalties for a patent which is owned by the Penn State Research Foundation (PSRF). This should be disclosed on page 3 in COINS.

• You receive business class airfare to Australia and hotel accommodations for five nights in Sydney from a professional society that you serve on a planning board. Even if you are not sure how much the ticket and hotel cost, this should be disclosed on Page 4 in COINS because it might reasonably have exceeded $5,000.
• You are a College of Medicine Investigator on a clinical trial and the sponsor has invited you to participate in an advisory board meeting and will reimburse/sponsor travel estimated at a cost of less than $5,000. The reimbursed/sponsored travel requires disclosure on Page 4 in COINS because of College of Medicine's $0 threshold for financial interests related to human participant research.

• You receive two nights in a hotel near Bethesda, MD, but did not directly pay for it or see the bill. As the cost reasonably would not exceed $5,000, you do not need to disclose this in COINS.
• You receive airfare and hotel accommodations from Argonne National Laboratory for research consulting over the summer months. As Argonne National Lab is a U.S. government entity, you do not need to disclose this in COINS.
• You were asked to speak at a week-long conference held at Michigan State University (MSU) and you stayed a few extra days to collaborate on a research project. MSU paid for some of your meals and hotel accommodations. As MSU is a United States institution of higher education, you do not need to disclose this in COINS.