POLICY TITLE: Carnegie Mellon University Policy on Conflict of
DATE OF ISSUANCE: This policy was originally issued to campus on 9/14/88 as
Organization Announcement #316, Policy on Conflict of
Interest/Commitment. The most recent revision was approved by the
President's Council on March 27, 2012.
ACCOUNTABLE DEPARTMENT/UNIT: Office of the Vice
President for Research. Questions on policy content should be directed to the
assistant vice president for research compliance, ext. 8-4727.
ABSTRACT: This policy addresses the circumstances in which
conflicts of interest or commitment may occur, provides examples of the
principles and processes outlined in this policy, and specifies a process for
resolving potential conflicts.
MISC: See also:
with Financial Conflicts of Interest Requirements
University Policy on Conflict of Interest/Commitment
Content of Policy
The university's principal missions are the education of students and the
generation and dissemination of knowledge. In pursuit of these missions, or as
a natural outgrowth of such activities, faculty and staff often become involved
in outside activities. While extramural activities benefit the university and
are generally encouraged, in some circumstances such activities give rise to
conflicts of interest or commitment.
This policy addresses the circumstances in which conflicts of interest or
commitment may occur, provides examples of the principles and processes
outlined in this policy, and specifies a process for resolving potential
conflicts. As used in this policy, the term "university members"
means faculty (including instructors and special faculty appointments), staff
(any employee of the university) and visiting faculty and staff.
University members should use good judgment, professional commitment and
ethics to protect themselves and the university from potential conflicts.
Administrators and supervisors should make employees aware of this policy and
create, by example, an atmosphere consistent with the university's missions.
addition to the guidelines and processes described below, some funding agencies
of the federal government require grantees to conform with
other disclosure and conflict of interest resolution procedures. Refer to the related policy Compliance with Financial Conflict of
Interest Requirements in Research for guidance on addressing conflicts of
interest related to externally funded research.
Interest and Commitment
Conflicts of interest occur when university members are in a position to
influence a decision on policy or purchases where they might directly or indirectly
receive financial benefit or give improper advantage to associates. Conflicts
of commitment arise when university members' involvements in outside
activities substantially interfere with their primary commitments to the
university: to teach, to conduct research and to meet related obligations to
students, colleagues and the university.
- All university members should make the fulfillment of
their responsibilities to the university the focal point of their professional
activities. University members should only become involved in extramural
professional activities insofar as they advance the mission or prestige of
the university and the activities do not interfere with their
responsibilities to the university. However, this policy is not intended
to unduly restrict involvement in outside activities.
- University members are traditionally allowed wide
latitude in defining their professional agenda and their degree of
involvement in outside activities. This tradition has served the
university well. In many circumstances, involvement in outside activities
promotes the university's missions and prestige. Consequently, the purpose
of this policy is to offer overall guidelines,
and not a list of particulars, for arranging outside activities and to
provide a mechanism for resolving potential conflicts of interest or
The following guidelines are not inclusive and are not without exceptions. They
provide examples of potential conflicts and processes for resolving them.
- University members in a position to influence a
university business decision for which they might receive material benefit
should disclose the nature of the conflict to others involved in the
decision. Whenever possible, those with potential conflicts should remove
themselves from involvement in the decision. If the individuals should
continue to participate in the decision process, discussion with
supervisors and documentation of the potential conflict should be
presented to the appropriate dean or department head.
- University members are regularly involved in consulting
activities from which they profit financially. As a rule, such activities
are not a conflict as long as:
The university actively encourages involvement in
professional organizations, panels, advisory commissions, and government,
charitable and community organizations. However, such involvement should
not become so dominant that university members no longer effectively
satisfy their responsibilities to the university. The counsel of colleagues
should be regarded as a valuable source of detached perspective on such
conflicts of commitment.
University members should not engage in direct
competition with the university either personally or through a firm in
which they have a substantial interest. For example, such a circumstance
may arise when an individual solicits a research award for which the
university is a competitor or would have been a competitor had the
individual properly acted as an agent of the university. In order to avoid
such potential conflicts, the individual should consult the appropriate
dean or department head.
Before contemplating outside employment or consulting
activities, university members should disclose to the appropriate dean or
department head potential conflicts of commitment or interest.
Faculty members must exercise prudence in directing
students and supervised employees toward activities from which the faculty
might financially benefit. The potential conflict is obvious, and faculty are encouraged to consult their dean,
department head or colleagues for an independent evaluation of the
activities' educational merits.
Graduate students should be discouraged from
consulting, especially as this distracts from their educational goals. In
particular, there is great potential for conflict of interest when
graduate students consult for spinoff companies; in this case, prior
approval of the department head must be obtained.
University members should not undertake or orient
university research at the expense of fulfilling the mission of the
university to serve the needs of an outside organization.
University members cannot withhold from the sponsoring
organization(s) for personal benefit any information that they have
acquired in connection with their sponsored research.
- i) University resources
(laboratories, studios, equipment, computational facilities and/or human
resources) are not more than incidentally used without reimbursing the
- ii) Such activities do
not unduly interfere with the time and energy committed by the
individuals to their primary responsibilities to the university. The
allowable amount of time dedicated to consulting will be governed by the Consulting Policy. University members should
adhere to the understood maximum of one day per week.
- iii) Such involvement
does not inhibit the publication of research findings developed in the
course of the individual's regular university activities.
Resolving Potential Conflicts
The first and most important line of defense against conflicts of interest
or commitment must be the university members themselves. Installation of a
quasi-judicial system for monitoring and adjudicating potential conflicts will
not serve the larger interests of the university. The university, therefore,
strongly encourages university members to disclose to the appropriate dean or
department head their outside commitments on a regular basis (e.g., during annual
departmental reviews, evaluations, or whenever those commitments undergo
significant change). Conflicts of interest related to research should be
addressed in the manner outlined in the related policy Compliance with Financial Conflict of Interest Requirements.
The university actively encourages an open academic environment where
teaching, conducting research and disseminating knowledge are the principal
goals of the institution. To further these missions, the university has relied
and shall continue to rely on the good judgment, professional commitment and
moral ethics of the university members to conduct themselves in a manner that
promotes objectivity, fairness and appropriate use of resources.
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