Institutional Conflict of Interest
Icon Policy Scope
The policy applies to all departments, centers and divisions of the College. Senior employees with contract signing authority, or those who could be seen or act as a representative of the College, which includes trustees, faculty and staff members, are required to complete an institutional conflict disclosure form in the event actual or potential conflicts arise. It focuses on conflicts that may interfere with the College's educational, research and operational integrity, particularly when financial gain to the institution or its units is involved.
Review the Institutional Conflict of Interest Policy
An institutional conflict of interest may arise when the College's financial relationships with external entities compromise its institutional values or decision-making integrity. This policy provides guidance for trustees, administrators, faculty and staff to recognize and manage both actual and perceived institutional conflicts, ensuring that the College's mission and decision-making processes remain objective and free from the influence of financial interests.
Icon Disclosure Requirements
Employees and applicable members of the College community must complete an Institutional COI disclosure form within (10) business days of its identification. Concerns about potential conflicts should be reported to the designated COI Administrator. The COI Administrator refers significant concerns to the COI Review Committee for further action. Disclosures under this policy is managed by the Office of General Counsel.
Retaliation against individuals reporting potential conflicts in good faith is prohibited. Misuse of the policy to report conflicts in bad faith is also a violation and subject to disciplinary action.
Example of a Potential Institutional Conflict of Interest
Scenario: The College is considering entering into a research partnership with a pharmaceutical company that has previously donated significant funds to the College's endowment. A senior administrator involved in the decision-making process holds a substantial amount of stock in the pharmaceutical company.
Explanation: While no improper actions have occurred yet, there are two potential conflict situations present here. First, the senior administrator's financial interest in the pharmaceutical company presents a potential conflict. Their financial stake could unduly influence their decision-making, potentially leading to bias in favor of the partnership, even if it's not in the best interest of the College. To manage this, the administrator should disclose their financial interest and possibly recuse themselves from the decision-making process regarding the research partnership. In addition, the fact that the pharmaceutical company is a large donor is also a conflict. This is because it could be perceived that the research results may be perceived to be influenced in favor of the company. To manage this conflict, the research should be carefully monitored to assure the integrity of the results.
Example of an Actual Institutional Conflict of Interest
Scenario: The College has entered into a business relationship with a technology company where a member of the Board of Trustees is a major shareholder. The company has provided substantial funding for a new research lab, and in return, the College has agreed to exclusively use the company’s products for its research projects.
Explanation: In this case, the financial relationship between the College and the technology company has already compromised the College’s decision-making integrity. The exclusive agreement limits the College’s ability to independently choose the best products for its research, potentially biasing the research outcomes in favor of the company. This situation constitutes an actual institutional conflict of interest, as the College’s decisions are directly influenced by the financial relationship with the trustee’s company. To address this, the College should re-evaluate the agreement and implement measures to ensure impartiality in its research activities.The company’s products should be used only when they are independently determined to be the best alternative according to the Procurement Policy and any applicable grant related requirements.
Disclosure Requirements
Disclosures under this policy would be made to and managed by the Office of General Counsel.