Conflicts of Interest

Conflict of Interest Processes at Boston University

Boston University has several different policies and procedures governing conflicts of interest and any reporting requirements that flow from those conflicts. The distinct processes are overseen by various offices around the University.

ways a coi gets processed

Conflict of Interest Policies, Processes, and Oversight Offices Explained

Different conflicts are governed by different policies and overseen by several University offices. To help you navigate this landscape, a more detailed chart is available that identifies:

  • Whether a situation constitutes a conflict
  • Which policy applies
  • How and where to report the conflict
  • Who to contact for guidance

Questions about Conflicts of Interest

For general conflict of interest questions, please reach out to the Compliance Services Office. Even if Compliance Services does not manage your particular conflict, we can help direct your inquiry to the appropriate office.

Compliance Services Office Role with Conflicts of Interest

Compliance Services oversees compliance with the Boston University’s Conflict of Interest Policy (COI Policy), which requires all trustees, officers, employees, and other representatives of the University to fully disclose any personal interests that might conflict with the University’s interests. The COI Policy implements standards set forth in the University’s Code of Ethical Conduct, with procedures to be followed when dealing with situations that may present a conflict of interest.

There are three ways employees report conflicts to the Compliance Services Office for review (as noted in the chart above): (1) Annual Disclosure, (2) Sourcing COI Process, and (3) Individual Reports.

  1. Annual Disclosure: Each year, Boston University asks Trustees (including Overseers and Trustees Emeriti), senior administrators, and selected faculty and staff to disclose financial, family, or organizational conflicts as defined by the University’s COI Policy .  Boston University’s Information Services & Technology group maintains an online portal and database [url: https://bu.edu/coi]  that serves as the reporting tool and repository of this information. When reports are made to the CSO, the conflict is logged and documented with the CSO.
    For more information about the Annual Disclosure process facilitated by Compliance Services, refer to our Frequently Asked Questions webpage.
  2. Sourcing COI Process: The Sourcing and Procurement Office (S&PO) receives notice of conflicts and potential conflicts in two ways: (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. Sourcing conflicts are vetted through the Compliance Subcommittee after review by CSO and coordination with the department, school, or college making the purchase.
  3. Individual Report: Any time a conflict arises, individuals to whom the policy applies are required to independently disclose that conflict to the CSO using a Conflict of Interest Disclosure Form appended to the Policy. For some individuals, this occurs at time of hire. For others, it occurs after a Sourcing and Procurement Conflict is approved, and the individual is asked to fill out a form. When reports are made to the CSO, the conflict is logged and documented with the office.

    Two additional COI policies and processes apply to distinct types of employees and conflicts, and are processed through other offices (and not Compliance Services). These are also noted in the chart above. They include:

    Types of Conflicts – more information

    Although a detailed chart is maintained on the Policies website to explain the various types of conflicts, policies involved, and conflict processes at Boston University, below is some additional information on the specific types of conflicts.

    Business or Financial Relationships

    Business or financial relationships includes 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.

    Faculty Consulting Relationships / Faculty External Professional Activity (Faculty only)

    In general, faculty consulting relationships are a Faculty External Professional Activity that require disclosure, and sometimes advance approval, in accordance with the Faculty Handbook Conflict of Commitment Policy to the Dean of the appropriate school or college, and in certain cases, the Associate Provost for Research. Individual schools maintain oversight over these consulting relationships.

    Medical Campus faculty may have additional reporting  obligations pursuant to research activities for your campus within the Boston Medical Center and Boston University Medical Campus Human Research Protection Program Policies and Procedures handbook, including 6.5 Investigator and Research Staff Conflict of Interest Policy and 6.6 Principal Investigator Responsibilities when Conducting Research. There is also the BMC Conflict of Interest Policy that might apply to the consulting relationship.

    Note that faculty consulting relationships could fall under the general Conflict of Interest Policy in certain circumstances. The Policy addresses business relationships between the University and faculty or staff, or companies that do business with BU in which faculty or staff (or their families) have a financial interest. Example: BU begins to do business with a company that employs a BU faculty member as a consultant. This example creates a financial conflict under the Conflict of Interest Policy, which would require additional reporting to the Compliance Services Office.  The form for reporting such conflicts is included in the Policy as a separate link.

    The Office of the General Counsel has additional guidance on the Personal Consulting of Faculty on their website.

    Family Conflicts

    Family conflicts includes any employee with a member of their immediate family (as defined in the Conflicts of Interest Policy) employed by the University.

    Service in Organizations

    Service in organizations includes 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” (as defined in the Conflicts of Interest Policy) does not include identifying organizations in which employees serve in their personal capacity. In accordance with the Policy, “covered Parties who serve at the University’s request or as the University’s representative as a director, officer, employee, or other agent of another organization shall turn over to the University any compensation received from such other organization for such service.”

    Staff Consulting and Outside Employment (staff only)

    Employees covered by the Employee Handbook “have an ethical duty to avoid an actual, potential, or perceived Conflict of Interest. 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.”

    Research Conflicts

    Financial conflicts of interest (FCOI) in research may occur when outside financial interests compromise, or have the appearance of compromising, the professional judgment of a researcher when designing, conducting, or reporting research. FCOIs are not inherently bad and do not always lead to biased behavior. For more information, refer to the Research Compliance website or email coi@bu.edu.

    The related policies are below:

    Investment Relationship Conflicts

    This type of conflict applies to “Trustees, Officers, University Advisory Board (UAB) members, and trustees emeriti” and requires that 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. Additionally, 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.

    Industry Relations (BUSM only)

    The Industry Relations Policy provides the standards by which all BUSM faculty/clinicians are expected to conduct themselves when dealing with industry. This only applies to faculty/clinicians at the Boston University Chobanian & Avedisian School of Medicine.

    Gifts to University Research or other activities from BU faculty or staff members

    The Gift Policy Manual governs 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.”

    Other Conflicts

    In accordance with the Conflict 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.