Financial Disclosure Policy

AUI Trustees and employees who have significant financial interests that would reasonably appear to directly and significantly affect their work with AUI or a Research Center must disclose the nature of these interests, not the monetary value, at the time of their appointment to the Board or employment with AUI.  Trustees and employees must also disclose the significant financial interests of their spouses or dependent children when that interest would reasonably appear to directly or significantly affect their work.

The term “significant financial interest” means anything of monetary value, including but not limited to:  (i) salary or other payments for services (i.e., consulting fees and honoraria); (ii) equity interests (i.e., stocks, stock options, or other ownership interests); and (iii) intellectual property rights (i.e., patents, copyrights, and royalties for such rights).  The term does not include:

  1. Salary, royalties, or other remuneration from AUI;
  2. Income from seminars, teaching engagements, or lectures sponsored by public or non-profit entities;
  3. Income from service on advisory committees or review panels for public or non-profit entities;
  4. Equity interests that, when aggregated for the employee and the employee’s spouse and dependent child(ren), meets both of the following tests: (i) does not exceed $10,000 in value as determined through references to public prices or other reasonable measure of fair market value and (ii) does not represent more than a 5% direct ownership interest in any single entity; or
  5. Salary, royalties, or other payments that, when aggregated for the employee and the employee’s spouse and dependent child(ren), are not expected to exceed $10,000 during any 12-month period.

Trustees and employees are not required to disclose other financial interests.  These disclosures should be updated annually or as new reportable financial interests are obtained.

Research Center Directors will review disclosures for their employees and will determine if the financial interest could affect the design, conduct, or reporting of sponsored research or educational activities.  The AUI President will review disclosures for the AUI Corporate Office staff and Research Center Directors.  The Chairman of the AUI Operations and Administration Committee will review disclosures for the AUI President.  AUI Legal Counsel will review disclosures for the members of the Board of Trustees.  All financial disclosures will be held confidential.

All financial disclosures and related activities will be kept for three years after the submission of the disclosure or longer if necessary.