Financial Conflict of Interest Policy

Purpose

This Financial Conflict of Interest (FCOI) Policy establishes standards and procedures for identifying, managing, and reporting financial conflicts of interest that may arise in connection with federally funded research, contracts, or projects conducted by Foxxception LLC.

This policy is designed to comply with federal regulations, including 42 CFR Part 50 Subpart F (Public Health Service), 2 CFR Part 200 (Uniform Guidance), and the Federal Acquisition Regulation (FAR) requirements for organizational conflicts of interest.

Company Information

Scope

This policy applies to:

• All owners, officers, and key personnel of Foxxception LLC
• Subcontractors and consultants working on federally funded projects
• Any individual who is responsible for the design, conduct, or reporting of federally funded work

Definitions

Financial Conflict of Interest (FCOI)

A significant financial interest that could directly and significantly affect the design, conduct, or reporting of federally funded work.

Significant Financial Interest (SFI)

A financial interest consisting of one or more of the following interests of the individual and their immediate family:

• Publicly traded entity: Remuneration exceeding $5,000 and equity interest exceeding $5,000
• Non-publicly traded entity: Any remuneration or equity interest
• Intellectual property rights and interests (patents, copyrights, royalties)
• Reimbursed or sponsored travel related to institutional responsibilities

Exclusions from SFI

The following are not considered Significant Financial Interests:

• Salary, royalties, or other remuneration paid by Foxxception LLC
• Income from seminars, lectures, or teaching engagements sponsored by government agencies or academic institutions
• Income from service on advisory committees or review panels for government agencies or academic institutions
• Investment vehicles such as mutual funds and retirement accounts where the individual does not directly control investment decisions

Disclosure Requirements

Initial Disclosure

All covered individuals must disclose all Significant Financial Interests prior to engaging in any federally funded project.

Annual Disclosure

Covered individuals must update their disclosures annually during the period of any federally funded project.

Ad Hoc Disclosure

Covered individuals must disclose any new Significant Financial Interest within 30 days of acquiring or discovering it.

Review and Determination

Foxxception LLC will review all disclosures to determine whether a Significant Financial Interest is related to federally funded work and whether it constitutes a Financial Conflict of Interest.

A Financial Conflict of Interest exists when:

• The SFI could directly and significantly affect the design, conduct, or reporting of the federally funded work
• The SFI creates an appearance of bias that could undermine public trust

Management of FCOI

If a Financial Conflict of Interest is identified, Foxxception LLC will develop and implement a management plan that may include:

• Public disclosure of the financial interest
• Monitoring of the work by independent reviewers
• Modification of the project plan
• Disqualification from participation in affected portions of the work
• Divestiture of the financial interest
• Severance of relationships that create the conflict

Reporting to Funding Agencies

Foxxception LLC will report identified Financial Conflicts of Interest to the relevant federal funding agency as required by applicable regulations, including:

• Initial FCOI reports prior to expenditure of funds
• Reports of newly identified FCOIs within 60 days
• Annual FCOI reports for ongoing projects

Public Accessibility

In accordance with federal requirements, Foxxception LLC will make information about identified Financial Conflicts of Interest available to the public upon written request within five business days. This information includes:

• The name of the individual with the FCOI
• The individual's title and role on the project
• The name of the entity in which the SFI is held
• The nature of the SFI
• The approximate dollar value of the SFI (ranges are acceptable)

Training

All covered individuals must complete FCOI training:

• Prior to engaging in federally funded work
• At least every four years
• When this policy is revised in a manner that affects requirements
• When an individual is found to be non-compliant with this policy

Enforcement and Sanctions

Failure to comply with this policy may result in:

• Removal from federally funded projects
• Termination of employment or contract
• Required repayment of funds
• Notification to federal funding agencies
• Other sanctions as appropriate

Record Retention

Foxxception LLC will maintain records related to FCOI disclosures, reviews, and management plans for at least three years from the date of final expenditure report submission or resolution of any government action involving the records, whichever is longer.

Subrecipient Requirements

When Foxxception LLC engages subcontractors or consultants on federally funded projects, we will:

• Require subrecipients to have their own FCOI policy compliant with federal regulations, or
• Require subrecipients to comply with this policy
• Include FCOI requirements in subcontract agreements
• Report any subrecipient FCOIs to the prime sponsor

Contact Information

For questions about this policy, to submit disclosures, or to request public information about FCOIs, please contact:

Policy Review

This policy will be reviewed annually and updated as necessary to ensure compliance with current federal regulations and best practices.