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.

Conflict of Interest Policies, Processes, and Oversight Offices Explained in a Chart 

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.

A chart has been developed to assist in determining if someone has a conflict,  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.

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 (CSO) Role with Conflicts of Interest

The Compliance Services Office (“CSO”) oversees compliance with the Boston University Conflict of Interest Policy (COI), which mandates that all Boston University trustees, officers, employees, and other representatives fully disclose individual interests that might conflict with the best interests of the University. The COI Policy is an extension of the University’s Code of Ethical Conduct, which sets forth the standards and procedures to be followed when dealing with situations that may present a conflict of interest.

There are three ways BU employees report conflicts to the Compliance Services Office (CSO) for review by the Compliance Subcommittee.

• Advance Disclosure: 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.
• 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 Conflict of Interest Policy .  Boston University’s Information Services & Technology group maintains an online portal and database (“COI Portal”) [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 Conflict of Interest process facilitated by the CSO, refer to our Frequently Asked Questions webpage.
• 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.

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 “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.”

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:

• • Boston University Investigator Financial Conflicts of Interest Policy for Research
  • BU DOE Interim COI Requirements-Addendum to BU FCOI Policy for Research
  • BU NASA Revised Requirements-Addendum to BU FCOI Policy for Research
  • Boston University Institutional Conflicts of Interest in Research Policy
  • Research Financial Conflict of Interest Review Process
  • Charles River Campus Institutional Review Board (IRB) Policies and Procedures

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.