402: Conflicts of Interest

Statement

Georgetown University employees must avoid conflicts of interest, or appearances of conflict, between their own personal or professional interests and the interests of the University.  All University employees are covered by this policy, including those who have access to proprietary University information that could be used for personal benefit, to benefit a University vendor, potential vendor or a competitor of a vendor. 

Philosophy

To avoid damage to the integrity of Georgetown University or its employees, the University has established procedures dealing with conflicts of interest. 

Procedures

Definitions 
A conflict of interest may occur if an employee:

• Has an existing or potential interest, financial or nonfinancial, that may impair (or appear to impair) the individual’s independent judgment when performing University responsibilities, or
• Receives or may receive a material, financial, or other benefit from knowledge of confidential or proprietary University information.

In addition, a conflict may occur if the above circumstances exist concerning a member of the immediate family or household of an employee, or an organization in which the employee or family member has a significant management, ownership, or material association. 

Requirements of Employees 
University employees must carry out their responsibilities to the University in a trustworthy manner and must be careful to avoid situations that could present a conflict of interest or an appearance of a conflict. 

If an employee believes that he/she is involved in a matter or is engaged in an activity in which a conflict of interest may exist, the individual must promptly and fully disclose the conflict to the appropriate department head, refrain from further participation in the matter until the question is resolved and follow any directions given by the University concerning the matter.  (If the employee is a department head, the conflict must be reported to the next higher level of management.) 

Responsibility

All University employees must follow the procedures outlined above. Other University policies may apply to conflicts of interest, including policies covering research, fiduciary responsibilities, and hospital affairs.  Refer to these policies for additional information, as well as the University policy on financial conflicts of interest.

Resources

Contact the appropriate Human Resources department if you have questions or if you would like more information about this policy.