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
|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
|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
|Investment Relationship Conflicts||University-wide Conflicts of Interest Policy||Trustees, Officers, University Advisory Board (UAB) members, and trustees emeriti
||General Counsel, Office of the General Counsel
|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
||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
||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 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:
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
|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 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
|Gifts to University Research or other activities from BU faculty or staff members||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.”
|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
General Counsel, Office of the General Counsel
|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
- Finance and Administration Policies Manual
- Code of Ethical Conduct
- President’s Statement of Commitment to Ethical Conduct
- Solicitation and Acceptance of Personal Gifts and Relationships with Vendors Policy
- Employee Handbook – Section 402 Conflict of Interest Policy
- Faculty Handbook section on Ethics and Activities, including:
- Supplier Code of Ethical Conduct
- Industry Relations Policy (BU School of Medicine only)
- Research Conflict of Interest Policies