There are several different types of conflict of interests at Boston University. These distinct conflicts are governed by different policies, and overseen\/facilitated through several offices.<\/p>\n
A chart<\/a><\/strong> has been developed to assist in determining if someone has a conflict,\u00a0 which policy governs, to help determine how to report that conflict to the appropriate office, and who they should reach out to for any guidance and assistance on next steps.<\/p>\n For general conflict of interest questions, please reach out to the Compliance Services Office<\/a>. Even if Compliance Services does not manage your particular conflict, we can help direct your inquiry to the appropriate office.<\/p>\n The Compliance Services Office (“CSO”) oversees compliance with the Boston University Conflict of Interest Policy<\/a> (COI), which<\/span>\u00a0mandates that all Boston University trustees, officers, employees, and other\u00a0representatives fully disclose individual interests\u00a0that might conflict with the best interests of the University. The COI Policy is an extension of the University\u2019s Code of Ethical Conduct<\/a>, which sets forth the standards and procedures to be followed when dealing with situations that may present a conflict of interest.<\/p>\n There are three ways BU employees report conflicts to the Compliance Services Office (CSO) for review by the Compliance Subcommittee.<\/p>\n Although a detailed Chart<\/a> 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.<\/p>\n Business or financial relationships includes any employee, or a member of an employee\u2019s immediate family, who has or proposes to have a business or financial relationship (as defined in the Conflicts of Interest Policy<\/a>) with Boston University, either directly or through another entity in which the employee or immediate family member has a significant interest.<\/span><\/p>\n In general, faculty consulting relationships are a Faculty External Professional Activity<\/strong> that require disclosure, and sometimes advance approval, in accordance with the Faculty Handbook<\/a>\u00a0Conflict of Commitment Policy<\/a> 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.<\/p>\n Medical Campus faculty may have additional reporting\u00a0 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<\/a>, including 6.5 Investigator and Research Staff Conflict of Interest Policy<\/a>\u00a0and 6.6 Principal Investigator Responsibilities when Conducting Research.<\/a> There is also the BMC Conflict of Interest Policy that might apply to the consulting relationship.<\/p>\n Note<\/strong> that faculty consulting relationships could<\/em> fall under the general Conflict of Interest Policy<\/a> 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<\/a>, which would require additional reporting to the Compliance Services Office.\u00a0 The form for reporting such conflicts is included in the Policy<\/a> as a separate link.<\/p>\n The Office of the General Counsel has additional guidance on the Personal Consulting of Faculty<\/a> on their website.<\/p>\n Family conflicts includes any employee with a member of their immediate family (as defined in the Conflicts of Interest Policy<\/a>) employed by the University.<\/span><\/p>\n Service in organizations includes any organizations as to which an employee serves as a director, officer, employee or other agent at the University\u2019s request or as the University\u2019s designated representative. \u201cOrganizations served\u201d (as defined in the Conflicts of Interest Policy<\/a>) does not include identifying organizations in which employees serve in their personal capacity. In accordance with the Policy, “c<\/span>overed Parties who serve at the University\u2019s request or as the University\u2019s 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.”<\/p>\n Employees covered by the\u00a0<\/span>Employee Handbook<\/a>\u00a0\u201care 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\u2019s immediate family has a financial interest that conflicts with the interests of the University.\u201d<\/span><\/p>\n 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\u00a0<\/span>do not always lead to biased behavior. For more information, refer to the\u00a0Research Compliance website<\/a>\u00a0or email\u00a0coi@bu.edu<\/a>.<\/span><\/p>\n The related policies are below:<\/p>\n This type of conflict applies to “Trustees, Officers, University Advisory Board (UAB) members, and trustees emeriti” and requires that n<\/span>o 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.<\/p>\n The Industry Relations Policy<\/a> 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.<\/p>\nQuestions about Conflicts of Interest<\/h3>\n
Compliance Services Office (CSO) Role with Conflicts of Interest<\/h2>\n
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\nFor more information about the Annual Conflict<\/strong>\u00a0of Interest process facilitated by the\u00a0CSO, refer to our\u00a0Frequently Asked Questions webpage<\/a><\/strong>.<\/li>\nTypes of Conflicts – more information<\/h2>\n
Business or Financial Relationships<\/h3>\n
Faculty Consulting Relationships \/ Faculty External Professional Activity (Faculty only)<\/h3>\n
Family Conflicts<\/h3>\n
Service in Organizations<\/h3>\n
Staff Consulting and Outside Employment (staff only)<\/h3>\n
Research Conflicts<\/h3>\n
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Investment Relationship Conflicts<\/h3>\n
Industry Relations (BUSM only)<\/h3>\n
Gifts to University Research or other activities from BU faculty or staff members<\/h3>\n