Conflict of Interest and Commitment Guidelines

These guidelines contain representative lists of (1) prohibited conflicts, (2) conflicts that may not be prohibited but must be disclosed for resolution or management, and (3) activities that are unlikely to involve conflicts. The University relies on members of the Brown community to apply the University’s mission statement, Conflict of Interest and Commitment Policy, and commonly accepted rules of ethical and professional conduct to identify conflicts not listed below.

1. Activities that are prohibited

The following are examples of conflicts of interest or commitment that are prohibited.

  • Hiring/supervising household members as employees.
  • Receipt of remuneration from Brown and an outside source for
    identical services or activities.
  • Use for personal gain of privileged University information, or assisting an outside organization in obtaining a preferred position with respect to such information.
  • Authorizing a consulting contract at Brown for a family member.
  • Solicitation for personal benefit of gratuities, favors, or anything of monetary value from students, donors, vendors, or contractors of the University.
  • Authorizing University-paid travel for a family member.
  • Voting on the award of University business to a vendor in which one has a significant financial interest or by which one is employed.
  • Authorizing a Brown donation to or purchase from an organization on whose Board one serves (see exception 3.b., below)

2. Activities that require disclosure and review

The following are examples of possible conflicts of interest or commitment. While all such conflicts must be disclosed, they may not all be prohibited. Some may be managed through administrative oversight and/or recusal of the disclosing individual in certain decisions at the University. Others may be considered sufficiently resolved through disclosure alone. Supervisors and senior officers who review disclosures are responsible for making these determinations and, when they determine there is a conflict that must be managed or eliminated, documenting the plan for resolution in writing and communicating it to affected parties.

  • Receipt of remuneration of $5,000 or more from another organization.
  • Having a significant financial interest in an organization that either has Brown as a large customer or supports the individual’s University activities.
  • Accepting gratuities, favors, gifts, or any other benefit of monetary value in one year equal to or greater than two hundred dollars ($200) from vendors, donors, students/parents, or employees whom you supervise or evaluate at the University.
  • Serving as an administrator when a spouse is employed at Brown or otherwise subject to this policy.
  • Negotiating forgiveness of Brown debt for a company in which one is invested.
  • Providing consulting services to an outside agency or (non-Brown affiliated) foundation that may give the University a preferred position with respect to grants or contracts.
  • Candidacy, election, or appointment to a public office.
  • Outside activities in which there is more than an incidental use of University facilities, equipment, and/or services.
  • Management, employment, consulting, and other contractual activities with, or ownership interest in, a business entity that competes with the University.
  • Participating in the negotiation of a contract between the University and an organization in which the Brown community member, a member of his or her family, or an associate has a significant financial interest.
  • Receipt of consulting fees or other remuneration from Brown University if one is a member of the Corporation or one of its Standing Committees.

3. Activities unlikely to involve a conflict

The following activities are unlikely to involve a conflict of interest and do not need to be reported unless they involve an amount of time or effort that introduces a conflict of commitment.

  1. Consultant services making use of the individual’s general research or professional background that do not involve a significant financial interest.
  2. Authorization of payment of dues and/or conference fees for professional organizations on whose board the individual serves.