Policy Statement on Investigator Financial Conflicts of Interest

The PPD™ Clinical Research business of Thermo Fisher Scientific is dedicated to promoting objectivity in research by ensuring that our services are free from bias. We comply with all federal regulations regarding investigator financial conflicts of interest (“FCOI”), including 42 CFR Part 50, Subpart F. Accordingly, we have implemented a comprehensive FCOI policy to safeguard the integrity of publicly funded research.

Our FCOI policy ensures research is performed with the highest ethical standards, maintaining public trust in the scientific findings. We are committed to upholding these standards and ensuring potential conflicts are managed appropriately to promote integrity and credibility. Therefore, our FCOI policy is predicated on the expectation that investigators conduct their affairs so as to avoid or minimize FCOI and respond appropriately when actual or potential FCOIs arise.

Our Commitment

• Transparency: The timely identification of potential FCOI is the first step in effective management. Accordingly, we require all investigators involved in public health service (PHS)-funded research to disclose any significant financial interests that may affect the design, conduct, or reporting of their research.
• Training: All investigators are required to complete training on our FCOI policy before engaging in PHS-funded research and on a reoccurring basis thereafter.
• Management: We have designated officials responsible for reviewing disclosures, determining the presence of FCOIs, and implementing management plans to mitigate any conflicts.
• Reporting: We provide initial and ongoing reports of FCOIs to the appropriate funding agencies, as required by applicable law. This includes details such as the project number, the name of the Investigator with the FCOI, the nature of the financial interest, and how it relates to the PHS-funded research. Similarly, PPD maintains disclosure forms, FCOI management plans, and related documents as required by law.

Public Accessibility

Information about identified FCOIs related to PHS-funded research is available upon request and in accordance with applicable regulations. For more information or to request a copy of our full Financial Conflicts of Interest policy, please contact us at FinancialConflicts.SM@ppd.com.