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67    INNO V AT O RS GUIDE  |  M ASS GENERAL BRIGH AM

                                  13
                                               Managing Conflicts

            13                                 of Interest (COI)














            Additional Mass General Brigham policies                              Special note regarding start-ups: There are a number of issues that

            and processes                                                         are unique to start-up ventures, whether they are undertaken with the
                                                                                  assistance of Innovation or independently. Innovators are advised to
            Outside activity | General policies. Mass General Brigham policy on   contact OII early in the process of forming a start-up for assistance in
                                                                                  identifying and handling those issues and in order to avoid complications
            consulting and other outside activities is found in Section 4 (the Consulting   with their official Hospital activities.
            Policy) of the Policy for Interactions with Industry and Other Outside
            Entities, http://www.partners.org/Assets/Documents/About-Us/OII/      An innovator’s services under any agreement to engage in
            OII_Policy.pdf. While Mass General Brigham encourages relationships   outside activities:
            with outside companies, it imposes some requirements on those         i.  Must not result in engaging in promotional activity;
            relationships in order to address potential conflicts, concerns about use of
            institutional resources and intellectual property, and other issues. Principal   ii.  Must not be performed during regular hours at Mass General Brigham;
            requirements include the following:                                   iii.  Must not involve use of students or trainees;

            i.  The Consulting Policy requires that most consulting or other      iv.  Must not overlap with Hospital responsibilities beyond simply being in
               engagements with a pharmaceutical or medical device company, or any   your general area of expertise;
               other vendor or potential vendor of Mass General Brigham, be covered   v.  Must not involve the inappropriate use of the institution’s name;
               by a written agreement.
            ii.  All written personal consulting agreements, with limited exceptions,   vi.  Must not involve the use of institutional funds or substantial use of
                                                                                     institutional resources; and
               must be reviewed by the Office for Interactions with Industry (OII)
               before the engagement to ensure compliance with institutional      vii. Must provide for no more than fair market value payment for the
               requirements set forth in the Consulting Policy. For details on the   services you are rendering.
               types of agreements that must be submitted to OII, please see:
               https://pulse.partners.org/resources_training/wikis/resources_wiki/
               interactions_with_industry/consulting__outside_activities.
            iii.  Innovators are responsible for ensuring that the terms of any
               agreement with an outside activity are consistent with the requirements
               of applicable Mass General Brigham policies, including but not limited
               to, the Consulting Policy and the Intellectual Property Policy.
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