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Conflict of Interest Policy Summary

Scottsdale Healthcare Corporation's ("SHC") ability to provide high quality medical care and conduct innovative research depends upon the integrity of each person involved and the confidence of the community it serves. The purpose of the Conflict of Interest Policy is to safeguard the integrity and reputation of SHC, and its medical staff, by fostering the proper and unbiased conduct of all hospital activities, by clarifying those Transactions that may involve a Conflict of Interest or the appearance of a Conflict of Interest, and to provide a framework for the approval of such arrangements.

A further purpose of the Policy is to promote objectivity in Research by establishing standards to ensure there is no reasonable expectation that the design, conduct, or reporting of funded research, including research under Public Health Service ("PHS") grants or cooperative agreements, will be biased by a conflicting financial interest of an Investigator.

As required by law, SHC will report any disclosed investigator financial conflict of interest (FCOI) prior to expenditure of PHS funds and certify that a management plan has been implemented at the time of the report.

Each investigator will complete training prior to engaging in research related to any PHS funding, and re-train at least every four years. Training will also be required immediately in the case of any FCOI policy change, when an investigator is new to the organization, or if an investigator is noncompliant with SHC’s FCOI policy or management plan.

Prior to the expenditure of funds, and within 60 days of identification or for an Investigator who is newly participating in a project, SHC will report to the National Institutes of Health (NIH) any and all FCOI reports. In addition, SHC will report to NHI annually the status of the FCOI and any significant changes to a management plan. If appropriate, SHC will report to NIH any update following retrospective reviews.

Information concerning FCOIs held by senior or key personnel will be made available within five days following a written request.