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Conflicts of Interest and Commitment Policy
This policy applies to exempt-level SEAS staff members
Policy Overview and Purpose
Members of the Harvard School of Engineering and Applied Sciences often interact in their private capacities with industry, government, community groups, professional organizations, and other non-Harvard entities during their employment with Harvard. While these interactions typically reflect favorably on the individual and Harvard, measures are necessary to avoid situations where these relationships could compromise or appear to compromise important academic values or the University’s business decisions. To assure Harvard’s many constituents of the integrity of our academic, research, and business endeavors, the University has had long-standing policies directing its most senior officials, among others, to act in a manner consistent with their responsibilities and to avoid circumstances where their financial or other personal ties to outside organizations could present an actual or potential conflict of interest or could discredit Harvard’s good name and reputation. In an effort to reinforce and enhance this philosophy, SEAS has adopted a similar policy for our Exempt Employees.
SEAS Exempt Employees are expected to consider their responsibilities to the University as their primary professional obligations and to avoid situations where their relationships could compromise actions by the School. This Policy is intended to give guidance to SEAS Exempt Employees about areas of potential conflicts of interest and conflicts of commitment so that conflicts, real or perceived, may be identified early, disclosed, and resolved appropriately.
To accomplish this objective, this Policy establishes an annual disclosure system whereby potential conflict situations will be identified at least once a year on a prescribed form (the “Disclosure Statement,” a form of which is available at Appendix B). Such a system promotes an understanding of the situations that may give rise to conflicts and raises the issue at least annually as a reminder of each SEAS Exempt Employee’s responsibilities.
Ideally, this Policy will promote early communication on these topics. The Disclosure Statement will be a vehicle by which actual and potential conflicts can be appropriately identified and resolved through early and open communication and discussion. In this spirit, and because conflicts do not necessarily manifest themselves at scheduled times, potential conflict situations and new relationships and activities are expected to be disclosed as they arise, in addition to being set forth in the annual Disclosure Statements.
Moreover, because the University’s business is so diverse and complex, it is not possible to capture every possible conflict in the appended form. SEAS Exempt Employees must be alert to areas of conflict that may be novel or unusual or particular to their functions. SEAS Exempt Employees who have questions about how this Policy applies to a particular situation, or about the Disclosure Statement itself, should seek advice from the Director of Human Resources.