The new Harvard University Policy on Individual Financial Conflicts of Interest for Persons Holding Faculty and Teaching Appointments (University Conflict of Interest Policy) is built upon 12 principles that establish a framework to guide the Schools in developing their implementation plans. The Schools’ implementation of the policy will be audited on a regular basis by the University’s Risk Management and Audit Services, and the audit reports will be reviewed by the vice provost for research and a new standing University Committee on Financial Conflicts of Interest.
Among other elements, the Schools’ plans must:
• Ensure that faculty members’ educational and research activities are motivated by a commitment to the advancement of knowledge and not compromised by their outside activities and financial relationships. A faculty member should avoid circumstances that reasonable observers would believe create an undue risk that the prospect of direct or indirect personal financial gain could inappropriately influence the faculty member’s judgment or actions in fulfilling his or her University duties.
• Include a robust system of annual reporting by faculty members of their and their immediate family members’ outside financial interests that may be related to their academic responsibilities. Additionally, the plans must include provisions for the reporting of new potential conflicts when they first arise.
• Require that written records be maintained by the School of the processes by which reported financial interests are reviewed and evaluated for the possibility of creating financial conflicts of interest that raise concern, and how such conflicts will be eliminated, reduced, or managed, as well as disclosed, to minimize the risk of undue bias of the faculty member’s research and scholarship, teaching, mentoring, and public service.
• Ensure that faculty members’ outside financial interests not adversely influence their instruction, guidance, or supervision of students (including trainees and postdoctoral fellows). Academic assignments to students should principally serve their interests in learning, self-development, and satisfaction of requirements for academic advancement.
• Provide for sanctions for failures to comply with the rules, reporting requirements, and other policy provisions.