Conflict of Interest
Amended date: 7/13/2023
Tufts employees are responsible for performing their duties in good faith and in the best interests of the University. In particular, employees are expected to avoid activities, agreements, business investments or interests, or other situations that materially conflict or appear to conflict with the interests of the University or interfere with the individual’s duty to loyally serve the University to the best of his or her ability.
A conflict of interest exists when an employee or a family member is in a position to benefit personally, directly or indirectly, from his or her relationship with a person or entity conducting business with the University. All employees have an obligation to avoid conflict, or the appearance of conflict, between their personal interests and the interests of the University and to avoid any situation that affects, or potentially could affect, his or her independent, unbiased judgment in the discharge of his or her duties to the University. An employee should recuse himself or herself from making any decision relating to University business when the employee is aware of circumstances that might reasonably cause his or her impartiality to be questioned.
To say that one has a conflict of interest does not necessarily mean that the individual involved acted or is expected to act inappropriately. However, if a competing interest exists that creates a conflict of interest concern, certain actions by the individual is required.
All employees are required to promptly report to his or her direct manager or senior manager any actual or perceived conflict of interest (as defined in accordance with the Business Conduct policy) which arises outside of the annual reporting period. The decision on whether to approve a reported conflict should be made by the Executive Vice President, after consulting with the employee's senior manager and such other University officials as the Executive Vice President may deem appropriate. Conflicts involving the Executive Vice President shall be reported to and approved or disapproved by the President. Additional information can be found in the Business Conduct Policy.
Update on Tufts COI Disclosure Process
Tufts has implemented a new internal platform for the collection and review of COI disclosures. Unlike the prior system, the new platform will be accessible to Tufts personnel at all times using their Tufts username and password and will carry forward the submitted data year to year, reducing the burden on the discloser. Annual updates to the disclosure will continue to be required when prompted; however, after this initial disclosure, individuals with no updates to their disclosure will only need to review and certify the accuracy of the prior submissions rather than re-enter all requested information each year.
As a reminder, in addition to the annual disclosure process, Tufts employees are required to disclose new significant outside financial interests within 30 days of entering into a relevant outside financial relationship or acquisition of gifts or monies which could be perceived as a COI within the individual’s role at Tufts. The single sign-on functionality of the new COI platform enables Tufts employees to access and update their existing data at any time.
This policy applies to all staff, temporary staff, postdoctoral scholars, faculty, independent contractors, affiliates or any other members of the Tufts community, including those hired contractually or who work under faculty or postdoctoral scholar handbooks, or who are otherwise covered by a collective bargaining agreement.
Detailed policies and answers to frequently asked questions can be found in the related links below.
Conflict of Interest and Conflict of Commitment Policies:
Conflict of Interest (COI) Policies:
Conflict of Commitment Policies:
Frequently Asked Questions: Conflict of Interest: FAQs
Related Links and Resources:
Business Code of Conduct: https://sites.tufts.edu/amas/controls-compliance/ethical-business-conduct/
Finance Division website: https://access.tufts.edu/purchasing
Postdoctoral Scholars’ Handbook: https://viceprovost.tufts.edu/policies-forms-guides/postdoctoral-scholars-handbook
This Conflict of Interest policy is part of the HR Employee Policies and Procedures that can be found at here.
Disclaimer: Changes to this policy and the handbook in which it is maintained may be made at any time, at the sole discretion of the University and is not a contract. Employment by the University is at will and either the employee or the University may end the employment relationship at any time.
Provided by Human Resources