Financial Conflict of Interest Policy

37degrees, Inc. policy on financial conflicts of interest in PHS-funded research.

A. Policy statement

37degrees, Inc. is committed to protecting research integrity by ensuring that the design, conduct, and reporting of research will not be biased by personal financial conflicts of interest.

B. Reasons for this policy

This policy conforms to Public Health Service regulations under 42 C.F.R. Part 50, Subpart F, requiring disclosure and training for individuals participating in PHS-funded research.

C. Definitions

  • Designated Official — person overseeing the financial conflicts-of-interest process.
  • Equity interest — stock, stock option, or other ownership interest.
  • Financial conflict of interest — a significant financial interest that could directly and significantly affect the design, conduct, or reporting of research.
  • Investigator — project director / principal investigator responsible for research design, conduct, or reporting.
  • Significant financial interest — financial interests of the investigator and immediate family, including:
    • Remuneration or equity > $5,000 in publicly traded entities
    • Any remuneration > $5,000 or equity in non-publicly-traded entities
    • Intellectual property income
    • Third-party sponsored travel related to institutional responsibilities
    • Positions of influence in non-37degrees entities

Exclusions from significant financial interests:

  • Salary paid by 37degrees
  • Ownership in 37degrees
  • Passive investment vehicles
  • Government / academic institution seminars or advisory service

D. Procedures

1. Designated Official responsibilities

  • Inform investigators of disclosure obligations
  • Review disclosures for conflicts
  • Maintain conflict-of-interest records
  • Report to PHS as required

2. Internal reporting requirements

Investigators must complete a Significant Financial Interest Disclosure (SFID) form before participating in research. Updates are required annually or within 30 days of acquiring new interests.

3. Determination and management

Upon identifying a financial conflict of interest, 37degrees implements a management plan with conditions such as:

  • Disclosure to participants and the public
  • Independent monitoring
  • Research-plan modification
  • Staff disqualification from portions of research
  • Divestiture of financial interests

4. External reporting requirements

37degrees discloses conflicts as required by law and posts information on its website. For PHS-funded research, we report unresolved conflicts within 60 days and conduct retrospective reviews if bias is suspected.

5. Confidentiality

Disclosures are protected to the extent possible and shared only on a need-to-know basis.

6. Investigator non-compliance

Failure to disclose may result in termination from research participation and mandatory disclosure in all public presentations of results for clinical research.

7. Training and education

Annual training is required; additional training is triggered by policy changes, new investigators, or compliance violations.

E. Retention of records

Records are retained for at least 3 years from the final-expenditure report submission. Public FCOI information is available upon written request and updated annually on 37degrees’ website.

For questions about this policy, contact team@37-degrees.com.