404A Conflict of Interest Policy
404A.1 Policy Statement
Employees are subject to the University’s Conflict of Interest Policy. Pursuant to the Conflict of Interest Policy, Boston University employees and other representatives of the University 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. See the University’s Conflict of Interest Policy for more information about what the University considers a conflict of interest.
404A.2 Familial Conflicts
As provided in the Conflict of Interest Policy, a Covered Party with a family conflict as defined in the Policy may require approval from the Office of the President at the time an offer of employment is extended to the applicant. Human Resources facilitates seeking approval from the President’s Office.
Even if a relationship falls outside of the Immediate Family definition in the Conflict of Interest Policy, all University employees are expected to avoid hiring or participating in the hiring process of a person with whom they have a close personal relationship. A close personal relationship might include romantic partners, close personal friends, or relationships where one party has a significant financial dependence on the other. Recusal may be appropriate in some circumstances. If recusal is not possible, the employee is expected to disclose the close personal relationship to others involved in the hiring process as soon as the conflict arises within the hiring process. Questions about this disclosure process may be directed to Human Resources Talent Recruitment Services staff.
404A.3 Reporting Conflicts of Interest
Employees who encounter one of the conflicts defined in the Conflict of Interest Policy (https://www.bu.edu/policies/conflict-of-interest/) should report that conflict in accordance with the procedures outlined within the Policy.
Additionally, Covered Parties as described in the Conflict of Interest Policy are part of the Annual Disclosure process and must complete an annual electronic Conflict of Interest Form when prompted each spring even if they have no conflicts to report.
If a conflict falls outside the scope of a conflict that require reporting to the University or it is not clear if reporting is required pursuant to the Conflict of Interest Policy, the employee must report the relationship to their direct Supervisor, who will advise if it needs to be reported.
404A.4 Additional Conflict of Interest Policies
Designated employees are required to comply with additional policies pertaining to conflicts of interest, including the Solicitation and Acceptance of Personal Gifts and Relationships with Vendors Policy (https://www.bu.edu/policies/giftpolicy/) and policies related to research conflicts of interest
Additional Resources Regarding This Policy
Related Policies and Procedures
- Employee Handbook Policies Manual (staff)
- 404A Conflict of Interest Policy [this Policy]
- 404B Conflicts of Commitment
- Code of Ethical Conduct
- Boston University Conflict of Interest Policy
- President's Statement of Commitment to Ethical Conduct
- Research Conflict of Interest Policies
- Faculty Handbook (faculty)
- Conflict of Commitment Policy (faculty)
Related BU Websites
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- Conflict of Interest Processes at Boston University - maintained on the Compliance Services Office Website
- Detailed COI chart maintained on the Policies website helps identify:
- Whether a situation constitutes a conflict
- Which policy applies
- How and where to report the conflict
- Who to contact for guidance
- Detailed COI chart maintained on the Policies website helps identify:
- Human Resources
- Where to Report a Concern
- Conflict of Interest Processes at Boston University - maintained on the Compliance Services Office Website
History
This Policy was revised and changed from 402 Conflict of Interest to 404A Conflict of Interest on July 1, 2026.
THIS POLICY IS PART OF THE EMPLOYEE HANDBOOK AND POLICIES MANUAL, AND SHOULD BE READ IN CONJUNCTION WITH ALL OF THE POLICIES THAT COMPRISE THE HANDBOOK. THE PROVISIONS OF THE EMPLOYEE HANDBOOK DO NOT CONSTITUTE AN EMPLOYMENT CONTRACT AND DO NOT ALTER THE AT-WILL STATUS OF AN EMPLOYEE.