Jaan Biotherapeutics, Inc.
Financial Conflict of Interest (FCOI) Policy
Effective: August 1, 2025
Introduction
The purpose of this policy is to ensure that research funded by the National Institutes of Health (NIH) is designed, conducted, and reported objectively and without bias resulting from Investigator financial conflicts of interest (FCOI). The 2011 revised regulations are 42 CFR Part 50 Subpart F “Promoting Objectivity in Research”, https://www.ecfr.gov/current/title-42/chapter-I/subchapter-D/part-50#subpart-F and 45 CFR Part 94, “Responsible Prospective Contractors”, https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-94, which set requirements for promoting objectivity in Public Health Service (PHS)-funded research for grants, cooperative agreement, and research contracts, respectively. The regulations do not apply to SBIR or STTR Phase I applications or awards. This policy implements the regulatory requirements for PHS/NIH grants and cooperative agreements.
Jaan Biotherapeutics, Inc. (“Jaan Biotherapeutics”, “The Institution”) adopts this policy for all Investigators (as defined below) engaged in PHS/NIH-funded research. It establishes processes to identify, disclose, and manage Investigator financial conflicts of interest to protect research integrity, ensure the safety of human and animal subjects, and maintain public trust in PHS/NIH-supported research.