Conflict of Interest Processes at Boston University

Conflict Type	Applicable Policy	Who It Covers	Managed By*	How and When to Report
Family Conflicts	University-wide Conflicts of Interest Policy	Any employee with a member of their immediate family (as defined in the Conflicts of Interest Policy) employed by the University	Compliance Services Office Associate Vice President for Compliance Services Nedra Abbruzzese-Werling	Advance Disclosure: When: When a conflict is identified Process: Individually file a COI Form Annual Reporting: When: Early Spring Process: “Selected Employees” (based on title, job duties, employment grade) and other representatives are required to file a disclosure form annually through a web-based COI Application indicating whether they have conflict. Employees who are required to file are prompted to do so via an email from Compliance Services at the start of the spring semester. New Hire Screening When: At hire Process: When a new employee is onboarded, the Human Resources Office asks about any family conflicts. Depending on the nature and proximity of the conflict, Human Resources will seek the approval from the Office of the President before the employee hiring is allowed to proceed.
Business or Financial Relationships	University-wide Conflicts of Interest Policy	Any employee, or a member of an employee’s immediate family, who has or proposes to have a business or financial relationship (as defined in the Conflicts of Interest Policy) with Boston University, either directly or through another entity in which the employee or immediate family member has a significant interest.	Compliance Services Office Associate Vice President for Compliance Services Nedra Abbruzzese-Werling Research Support/Research Compliance Office Gloria Waters, Vice President and Associate Provost for Research Kate Mellouk, Associate Vice President for Research Compliance Technology Development Office (“OTD”) Michael Pratt, Managing Director – for faculty companies Kathryn M. Mellouk, Associate VP, Research Compliance – for sponsored research matters	Advance Disclosure: When: When a conflict is identified Process: Individually file a COI Form Annual Reporting: When: Early Spring Process: “Selected Employees” (based on title, job duties, employment grade) and other representatives are required to file a disclosure form annually through a web-based COI Application indicating whether they have conflict. Employees who are required to file are prompted to do so via an email from Compliance Services at the start of the spring semester. Sourcing COI Process: When: When Sourcing and Procurement Office (S&PO) receives notice of conflicts and potential conflicts: (1) through vendor self-reporting when they register in the SP&O registration system as required of all first-time vendors; or (2) through an office, department, or employee contact who notifies SP&O of a conflict requiring review. Process: Compliance Services Office receives notice of the conflict, asks for additional information from the department purchasing from the vendor, and then provides information to head administrator over department and Compliance Subcommittee for review and approval. Academic Collaborations with Industry/License of BU IP: When: When the Technology Development Office (OTD) licenses BU-owned IP to a company in which a BU employee (typically a faculty member) has a financial interest, or when a company leasing space in one of BU’s business incubators (Photonics, or BioSquare) has a BU-person affiliated with the company (oftentimes it is a faculty spin-off/start-up company). Process: Business or Financial Relationships and Investment Relationships arising from academic collaborations with industry as described above should be reported through the Disclosure and Authorization Form, which specifies the approval required to move forward with the proposed transaction. University personnel who approve academic collaborations with industry should consult with the Compliance Subcommittee about any proposed transactions of concern, and provide all approved DARFs to the Compliance Services Office.
Service in Organizations	University-wide Conflicts of Interest Policy	Any organizations as to which an employee serves as a director, officer, employee or other agent at the University’s request or as the University’s designated representative. “Organizations served” does not include identifying organizations in which employees serve in their personal capacity.	Compliance Services Office Associate Vice President for Compliance Services Nedra Abbruzzese-Werling	Advance Disclosure: When: When a conflict is identified Process: Individually file a COI Form Annual Reporting: When: Early Spring Process: “Selected Employees” (based on title, job duties, employment grade) and other representatives are required to file a disclosure form annually through a web-based COI Application indicating whether they have conflict. Employees who are required to file are prompted to do so via an email from Compliance Services at the start of the spring semester.
Investment Relationship Conflicts	University-wide Conflicts of Interest Policy	Trustees, Officers, University Advisory Board (UAB) members, and trustees emeriti No trustee or Officer, or a member of his or her Immediate Family may knowingly directly invest in any Investment Vehicle in which the University has a Material Financial Interest. The University will not knowingly directly invest in an Investment Vehicle in which a trustee or Officer, or a member of his or her Immediate Family, has a Material Financial Interest, except with the prior approval of the Audit Committee.	General Counsel, Office of the General Counsel Erika Geetter, Senior Vice President, General Counsel, and Secretary of the board of Trustees Board of Trustees Chairman of the Audit Committee	Advance Disclosure Trustees, Officers, University Advisory Board (UAB) members, and trustees emeriti must provide advance written disclosure of any proposed Business or Financial Relationship or Investment Relationship they or members of their Immediate Family have or propose to have with University, either directly or through another entity in which they have a Significant Interest, to the General Counsel and Chairman of the Audit Committee using a Conflict of Interest Disclosure Form. If a trustee or Officer is uncertain whether to disclose a particular business or financial relationship, the General Counsel or Chairman of the Audit Committee should be consulted. An amended form must be filed promptly in the event of a material change in circumstances. Annual Disclosure Process Trustees, Officers, UAB members, and trustees emeriti must complete and return the Conflict of Interest Disclosure Form distributed annually by the University to either confirm an ongoing Business or Financial Relationship, Investment Relationship or Employment Relationship or indicate the absence of any such relationship.
Research Conflicts, including Consulting for a Research Sponsor	Investigator Financial Conflicts of Interest Policy for Research	In the research context, each Investigator responsible for the design, conduct or reporting of research at or under the auspices of BU must disclose all of his or her Significant Financial Interests (SFI), and those of the Investigator’s spouse and dependent children, that reasonably appear to be related to the Investigator’s Institutional Responsibilities. Faculty should be sure to report all international collaborations as required by specific funding agencies.	Research Support/Research Compliance Office Gloria Waters, Vice President and Associate Provost for Research Heather Skinner, Assistant Director, Research Integrity FCOI/EC Pamela Richmond, Executive Director, Research Compliance Kate Mellouk, Associate Vice President for Research Compliance	All individuals responsible for the design, conduct, or reporting of research at Boston University must Complete a Financial Interest Disclosure. When: At the time of proposal submission and annually thereafter, and within 30 days of receiving a new outside financial interest. Process: Contact the COI Program if you cannot complete the online form.
Research conflicts involving financial interests by the University or key individuals	Institutional Conflicts of Interest in Research Policy	1. BU as an institution and the financial interests held BU’s name and over which the University has direct control; and 2. Financial interests of key individuals* who, because of their positions, have influence over what research is or is not conducted and whose responsibilities include review or oversight of research. *Key individuals = See Policy, Section III. Definitions	Office of Sponsored Programs, Research Support/Research Compliance Office for the Advisory Committees on Research Conflict of Interest Heather Skinner, Assistant Director, Research Integrity FCOI/EC Pamela Richmond, Executive Director, Research Compliance Kate Mellouk, Associate Vice President for Research Compliance	When: There is not a separate process for reporting these institutional conflicts. Rather, they are evaluated during regular review of Investigator COI Policy for Research (as described above). No conflicted situation will be permitted unless, upon review, it is deemed manageable through a management plan that is transparent, principled and can withstand the highest level of ethical and scholarly scrutiny.
Faculty External Professional Activity (Faculty only)	Faculty Handbook Conflict of Commitment Policy	BU faculty members engaging in External Professional Activities. External Professional Activities are activities outside of Boston University that utilize the expertise or knowledge the faculty member has developed or is developing in carrying out their University responsibilities in teaching, research or service. The policy prohibits “Faculty members who have full-time appointments …from holding a full-time or part-time tenured or tenure-track position at another educational institution, or any position which would be considered a permanent or primary position or constitute more than 20% time at the other institution.”	The dean of the faculty member’s school or college	When: Annually – Every faculty member must submit annually the External & International Activity Report (EIAR) to their dean which should include any activities that require pre-approval. After reviewing the report, the dean or dean’s designee will seek to resolve with the faculty member any concerns about the faculty member’s activities or refer the concerns to the appropriate provost if a resolution cannot be achieved. Advance Disclosure, Prior to the Activity – Prior Written Approval by the Dean or Dean’s Designee is required for the following activities: External Teaching or Course Development Compensated Appointments at Other Educational Institutions Certain Activities with Outside Entities External Professional Activities Involving BU Students Prior Written Approval of the Vice President & Associate Provost for Research is required for Service as PI or Co-PI for Other Entities. Process/How to Report: CRC faculty complete the EIAR (along with the Faculty Annual Report) in the My CV system. The reports open to CRC faculty in January and are supposed to be completed in March of each year. Medical Campus faculty have their own system for reporting such activity.
Staff Consulting and Outside Employment (Staff only)	Employee Handbook – Section 402.2 Conflict of Interest	Employees covered by the Employee Handbook “are required to avoid ethical, legal, financial, or other conflicts of interest and to ensure that their activities and interests do not conflict with their obligations to the University or its welfare. A conflict of interest may exist if an employee or a member of the employee’s immediate family has a financial interest that conflicts with the interests of the University.”	Human Resources	When: An employee who encounters a personal interest that may have the potential of conflicting with the interests of the University is required to discuss immediately the matter with his or her supervisor. Supervisors are responsible for notifying the University’s Office of General Counsel of conflict-of-interest situations. Designated employees are required to comply with additional policies adopted by the Trustees of Boston University.
Industry Relations (BUSM only)	Industry Relations Policy (BUSM only)	Faculty/clinicians at the Boston University School of Medicine The Policy provides the standards by which all BUSM faculty/clinicians are expected to conduct themselves when dealing with industry.	BUSM Executive Committee	DISCLOSURE of RELATIONSHIPS with VENDORS When: Annual Disclosure Process Faculty/clinicians must fully disclose all relationships with vendors on an annual basis through the reporting mechanisms of Boston University School of Medicine and Boston Medical Center. Advance Disclosure Faculty/clinicians engaged in speaking or consulting that is compensated by vendors must have approval from the Department Chair prior to providing the service. If the Department Chair has personal financial interest in the same entity as that proposed for the member, the Department Chair should recuse himself or herself and the approval should be granted by the Dean of BUSM. Publishing Work Faculty/clinicians must disclose all of their related financial interests, including past, existing or expected interests (e.g., grants and sponsored research, compensation from consulting, speaker’s bureaus, advisory boards; investments and ownership interests) to journal editors in manuscripts submitted for publication, and audiences at lectures or presentations. Institutional Deliberations Faculty/clinicians must disclose their actual and potential conflicts of interest related to any institutional deliberations and generally may not participate in deliberations in which he or she has an actual or potential conflict of interest. See Boston University Conflict of Interest Policy (http://www.bu.edu/ethics/conflict.pdf) and Boston Medical Center Conflict of Interest Policy (No. 9.4). Conflicts arising from Supervision Faculty/clinicians with supervisory responsibilities for trainees must ensure that the instructor’s conflict or potential conflict of interest does not affect or appear to affect his or her supervision of the activities or responsibilities of the trainee or staff member.
Gifts to University Research or other activities from BU faculty or staff members	Gift Policy Manual	BU employees (faculty or staff) making gifts to university research or activities. Per the Policy: “Gifts from faculty members to support their own research can only be accepted if the gift is for a specific University purpose. Contributions can not be set aside for the specific use of a person or persons but can be directed to a specific department, program or research area.”	Comptroller’s Office 617-353-2290	In order for the donation to be treated as charitable (and therefore eligible for a deduction), it is important that the donor with the conflict (interested faculty or staff member) not have any direct control over expenditures from the fund. When these situations arise, the Department head should contact the Comptroller’s Office, who will consult with other offices as necessary
Other Conflicts	University-wide Conflicts of Interest Policy	A Conflict of Interest exists when a Covered Party’s direct or indirect personal interests are inconsistent with or interfere in any way with the best interests of the University. Covered Parties include: Trustees, Officers, University Advisory Board members, and Trustees Emeriti, non-officer employees and representatives.	Compliance Services Office Associate Vice President for Compliance Services Nedra Abbruzzese-Werling Direct Supervisor General Counsel, Office of the General Counsel (for oversight of Trustees, Officers, University Advisory Board members, and Trustees Emeriti)	When: Any other relationships or interests that might conflict with the best interests of the University should also be disclosed for review to suprvisors and/or the Compliance Services Office using the COI Form.

Related Policies and Procedures

Conflict of Interest Processes at Boston University

DISCLOSURE of RELATIONSHIPS with VENDORS