AmberGen Inc. Company Policy – Financial Conflict of Interest (FCOI) Policy, August 24th, 2012
Objective research is of paramount importance to AmberGen and our subgrantees and defined vendors herein, to ensure public trust and meet scientific, program and ethical goals of our National Institutes Health (NIH) grant efforts. To address the increasing complexities related to financial interests held by biomedical and behavioral researchers, the Public Health Service (PHS) and the Office of the Secretary of the U.S. Department of Health and Human Services (HHS) has published their final rules. AmberGen believes we have fully addressed the requirements (including those of our defined sub-level vendors) of this ruling although we will continue to update this policy as needed, particularly related to any changes in personnel FCOI issues or upon further DHHS guidance.
Effective August 24, 2012, AmberGen’s policy requires that each investigator, subrecipients, subgrantees and collaborators affiliated with AmberGen, by NIH or any other applicable grant or contract, be in compliance with 42 CFR Part 50, Subpart F for PHS grants and cooperative agreements (and 45 CFR Part 94 for contracts). In addition, this legislation spells out NIH’s commitment to preserving the public’s trust that the research supported by them is conducted without bias and with the highest scientific and ethical standards. AmberGen intends to use this same FCOI standard for all other Federal agency grant and contract efforts, as tailored or amended accordingly.
The following are key term definitions and AmberGen’s policy guidance for principal or program investigators, subrecipients, subgrantees and collaborators affiliated with AmberGen. This policy and all FCOI AmberGen guidance are also available at http://www.ambergen.com/fcoipolicy/ (or this document, the Financial Conflict of Interest (FCOI) Policy, August 24th, 2012, Addendum A, to AmberGen’s Employee Handbook) so that all interested parties, including the general public have access to this Company policy.