Financial Conflicts of Interest Policy

Policies and Guidance

On May 26, 2010, the President and Fellows of Harvard College approved a University-wide policy on Individual Financial Conflicts of Interest (pdf). This policy, revised in May, 2012, provides guidance for school deans, faculty and other individuals holding teaching appointments, in identifying, evaluating, and managing conflicts of interest.  The policy is confined to issues arising from a financial conflict of interest, defined as:

“…a set of circumstances that reasonable observers would believe creates an undue risk that an individual’s judgment or actions regarding a primary interest of the University will be inappropriately influenced by a secondary financial interest.”

The University has a primary interest in preserving and furthering institutional integrity, ethical conduct, and public confidence and trust in all academic and research pursuits, an interest it shares with every faculty member.   Faculty members inevitably hold legitimate secondary interests as well, ranging from career advancement to obtaining or renewing sponsored research funding.  Although these secondary interests often align with the core mission and values of the University, they may at times occasion a departure from the University's and faculty member’s shared primary interests.

The university-wide policy provides a framework for implementation that allows for some flexibility among the various Schools in recognition of their wide variance in culture, mission, and the nature of acceptable faculty interactions with external entities.  Each School's approach to implementation of the policy is described in a School Implementation Plan.

The University Policy is supplemented by procedures specific to the implementation of the August 25, 2011 Public Health Service Rule (pdf).

Faculty at the Medical School should refer to the website of the Office for Academic & Research Integrity for HMS-specific policies and procedures.  In addition to complying with the Medical School's conflict of interest policy, Medical School faculty are also expected to comply with their hospital's conflict of interest rules.

On September 14, 2020, the President and Fellows adopted an additional policy on Institutional Conflicts of Interest (PDF). That policy governs how possible conflicts between the institution’s own financial interests and its primary interests as defined above.