Conflict of Interest
WPI 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.
Definition of Conflict of Interest
A conflict of interest exists when an employee is in a position to benefit personally, directly or indirectly, from his or her relationship with an entity or person conducting business with WPI. All employees have an obligation to avoid conflict, or the appearance of conflict (e.g., accepting gifts from external vendors; contracting relatives to do work for WPI), between their personal interests and the interests of the university.
Examples of typical conflict situations are:
- The current or potential involvement of the employee, or a member of his or her family, in a financial or other relationship that affects, or potentially could affect, his or her independent, unbiased judgment in the discharge of his or her duties to the university. A conflict of interest could arise, for example, from an employee's compensated service as a consultant to, or membership on, a board of directors or a managerial role with respect to an entity doing business with the university.
- The possession on the part of the employee, or a member of his or her family, of a significant ownership interest in an organization conducting business with the university.
- Receipt of gifts or other payments or services of financial value from persons or entities doing business with the university other than those specified under "Gifts and Entertainment."
"Family" members shall mean spouse, parents, siblings, children, grandparents, grandchildren, aunt/uncle and their spouse, niece/nephew and their spouse, any in-laws, step relationships or persons living in employee's same household.
Reporting Conflicts of Interest
While all WPI employees are required to avoid conflicts of interest or the appearance of conflicts, certain individuals are required to disclose annually the existence or absence of defined conflict situations. These employees include all faculty and designated exempt staff.
Faculty, division heads, and other designated individuals (including staff who are elected officers of the corporation and those having signature authority for the university) will file an annual written disclosure of conflicts of interest or situations having the appearance of conflict with the Provost’s Office (faculty) or the Compliance Office within the Division of Finance and Operations (designated exempt staff) on forms provided by the university, but are required to report promptly all conflicts of interest whenever they arise.
Questions will arise as to whether a specific situation constitutes a conflict of interest. Employees are urged to conduct themselves cautiously and, whenever in doubt, to report the situation to the General Counsel.
Failure to disclose a reportable interest or relationship or neglecting to comply with the university's requirements for managing a determined conflict of interest may subject the employee to disciplinary action.
Resolving Conflicts of Interest
With respect to faculty, the Provost and the General Counsel will determine appropriate and necessary actions. With respect to staff, the General Counsel and the Executive Vice President will consider appropriate actions.
Questions & Answers
Q. I intend to use outside printing services to develop the layout for a new student services brochure to be issued next semester. My wife runs a printing and design shop that can perform this type of work. Can I direct the business to her?
A. No. There exists a potential conflict of interest since by providing this job to your wife (or any other family member or persons living in your household) you might personally benefit. Also, this situation could affect your unbiased judgment in selecting the most qualified print shop for the project. Therefore, you should not negotiate or approve a contract with the shop.
Q. I have an outside consulting practice that solicits business from several sponsoring agencies that provide funding awards to WPI. Do I need to disclose this relationship?
A. Yes. This relationship must be disclosed via the annual disclosure process to determine if any potential conflict exists between your outside business and WPI in terms of competing for similar awards of projects and funds from these agencies. Work performed by a university employee in a self-owned business or as an employee of an outside business which directly or indirectly places the university at a financial or competitive disadvantage will not be permitted.
Q. I am a computer systems support staff person to several departments on campus. Last week, one of the department’s managers asked me if I could come over to his house that weekend and assist with some set up work on his personally owned computer he recently purchased. I found it hard to say no to his request since I perform the same function for the university. Is this a conflict of interest on his part?
A. Yes. This would constitute a conflict of interest. Supervisors may not make such requests. This situation can be compared to one in which a supervisor receives a gift from a vendor. Many such gifts are forbidden by our policies because they may cause the supervisor to feel beholden to the vendor or give the vendor power to coerce the supervisor. In the case of an employee, receipt of a "gift" of the employee's time creates the same opportunity for a conflict of interest, where the obligation of loyalty to WPI becomes secondary to other interests. This is true even if the work is, or appears to be, performed voluntarily; it need not be coerced to be wrong.
Q. I am a researcher at the university who is involved in a start-up company in which I own a 5% interest. Do I need to disclose this?
A. You need to report your interest if the company conducts or is likely to conduct business with the university. This question is specifically asked on the annual disclosure statement.