Conflict of Interest Guidance for Family Members
I. Family Members
Brown University (“Brown” or “the University”) defines a Family Member as a spouse, domestic partner, parent, child, sibling, grandparent, grandchild, in-laws, and step parent, step child, guardian and ward, or member of one's household.
II. Transparency and Reporting
Since family relationships are not always widely known, it is important to be transparent when a Family Member is working at Brown. Therefore, members of the Brown community must take the following actions with respect to their Family Members:
- Report the relationship to supervisors if there is work-related interaction or potential interaction between you and your Family Member;
- Report the relationship, as required, on University Conflict of Interest (COI) disclosure forms; and
- Ensure that any management measures that are implemented as a result of the relationship are known to any individuals who may need to monitor, or otherwise participate in, such management.
III. Other Relationships that Could Create Conflicts of Interest
While Brown’s Conflict of Interest Policy focuses primarily on managing conflicts of interest that arise in connection with Family Members, it is important to be cognizant of conflicts that can arise due to other personal or business relationships. Therefore, University policy requires that you disclose any other relationship that does not involve a Family Member but that is, or may be perceived to be, a conflict of interest so that the relationship can be managed properly.
Examples of individuals and relationships that may create, or may be perceived to create, conflicts of interest, include:
- extended family, such as cousins, aunts and uncles;
- having a close friendship or relationship with someone;
- a business associates; and
- a landlord.
IV. Prohibited Activities Involving Family Members
The University’s Conflict of Interest and Conflict of Commitment Policy prohibits members of the Brown community, including staff and academic appointees, from participating in decisions involving a direct benefit to a Family Member. This includes:
- Directly supervising or evaluating a Family Member;
- Hiring or directing another individual to hire a Family Member;
- Setting salary for a Family Member and/or participating in discussions related to their salary or promotion;
- Authorizing a consulting contract for a Family Member; and
- Authorizing University-funded travel for a Family Member except as otherwise permitted by University policy.
V. Serving in a Role with Functions and Responsibilities that Could Affect a Family Member
Conflicts are not restricted to circumstances in which Family Members work in the same department. Family Members may be working in different departments; however, if one Family Member is serving in a role with functions and/or responsibilities that could (a) lead to direct interactions with a Family Member, or (b) could affect, or be perceived to affect, a Family Member, this can create a conflict that needs to be reviewed and, if necessary, managed. If you have a conflict or potential conflict caused by a workplace interaction with a Family Member, you must notify your supervisor.
The supervisor, in collaboration with the Office of Human Resources and/or the Office of Faculty Affairs, must review the interactions and resulting conflict of interest and, if necessary, develop a written management plan to address the conflict(s). In some instances, you may be required to recuse yourself from making decisions involving the Family Member.
VI. Committee Service
When serving on a University committee that is reviewing a case involving a Family Member OR deciding on a matter that could directly affect a Family Member, you must either recuse yourself or inform the committee and its Chair of the relationship, in which case you may be asked to recuse yourself from voting or making decisions on the case.
- Serving on a committee that is reviewing a complaint involving your Family Member.
- Serving on a committee that is making a decision that could affect a particular group of people, and your Family Member is part of that group.
You are expected to also abide by any committee-specific policies regarding conflicts of interest involving Family Members and any disclosure and/or recusal requirements set forth in such policies.
VII. Teaching or Evaluating Students Who Are Family Members
The University prohibits members of the Brown community, including staff and academic appointees, to participate in decisions involving a direct benefit to Family Members. This prohibition also includes evaluating or grading a Family Member.
If you have a Family Member who is a student at Brown, you should not be involved in grading or evaluating this Family Member. If a situation arises where a Family Member is required to take a class or seminar you teach or co-teach or with which you assist, or is required to complete a project you are evaluating, this should be discussed with your Cognizant Dean, the Dean of the College's office, or the Graduate School before the Family Member enrolls in the class. These offices will coordinate with your department to assess the conflict and develop a management plan that will ensure that your Family Member is graded and/or evaluated by an independent party.