Institutional Conflict of Interest Policy

Policy Summary

The George Washington University’s (“GW” or “university”) mission of education and research benefits from financial relationships and collaborations with external entities. There can be, however, a conflict between the university’s responsibilities as an educational and research institution and (a) the financial interests of the university, (b) the interests of those who have authority or influence over institutional policy or decision-making (“Covered Individuals”), or (c) external funders of university activities. This policy addresses situations in which a university interest creates an actual, potential, or perceived institutional conflict of interest related to decision-making on the part of university personnel, or the objectivity of research or education. Members of the university community are expected to disclose such potential interests and the university will examine through an institutional conflicts of interest review process whether an institutional conflict of interest exists and the potential strategies to manage, mitigate, or eliminate the conflict. 

Who is Governed by this Policy 

• The university and Covered Individuals who have authority to act on behalf of the institution. Covered Individuals include but is not limited to, Board of Trustees, President, Provost and Executive Vice President for Academic Affairs, Vice Provosts, Executive Vice President and Chief Financial Officer, Vice President for Health Affairs, vice presidents, deans, vice and associate deans, department chairs, and other institutional administrators, particularly individuals having oversight of research, with special attention to human subject research. This policy also requires reviews of conflicts of interest involving department chairs, division chiefs, institute and center directors, Institutional Review Board chairs, the Conflict of Interest and Institutional Conflict of Interest committee chairs, and chairs of other similar committees that might be created in the future. 

Policy

In pursuing its mission, the university must conduct its activities free of improper influence. An institutional conflict of interest exists when a financial relationship between the university and an external entity compromises the integrity of institutional responsibilities or decision-making. An institutional financial relationship may be created by gifts, payments, grants, royalty income, or other benefits provided to the university from external sources or from equity interests held by the university in other entities. Institutional conflicts of interest may involve any university activity carried out in the pursuit of the university’s mission in which the judgement of those involved has the potential to become affected by the university's financial relationship. Of particular concern are conflicts that arise in any educational, administrative, or research decision-making process or in the conduct of research involving human subjects. 

This policy does not require that the university refrain from conducting university business with external entities that have a separate financial relationship with the university. However, in such instances, potential institutional conflicts of interest must be identified promptly and resolved appropriately. Additionally, this policy does not govern the reputational review of a gift, payment, grant, royalty income, or other financial benefit provided to the university. (See related information.) 

Review for Institutional Conflicts of Interest 

To evaluate potential institutional conflicts of interest, the Office of Ethics, Compliance, and Risk in consultation with the Office of General Counsel will bring forth matters to a review committee (e.g., Executive Research Oversight Committee). Participant inclusion shall ensure the review is conducted by individuals with sufficient independence, expertise, and adequate institutional representation. 

Potential Strategies to Address Institutional Conflicts

In determining whether a potential institutional conflict of interest exists, the committee will assess whether the university’s financial relationship with the external entity or an individual’s authority for policy or decision making actually, potentially, or could be perceived as (1) compromising the integrity of the university in fulfilling its mission(s), and (2) being unduly influenced by the expectation of gain to the university or one of its units from the external financial relationship.

Should it be determined that there is a potential, perceived, or actual institutional conflict, the following are potential options, not exhaustive, to manage, mitigate, or eliminate institutional conflicts of interest: 

• Public disclosure of financial interests; 

• Instituting safeguards in the research such as external monitoring, independent review, recusal by the official, alternative supervisors, disclosure requirements; 

• Divestiture of financial interest of the university or individual; 

• Acceptance or rejection of a gift or contract; 

• Reducing or modifying the financial (equity or royalty) stake involved; 

• Recusal of individuals whose personal financial interests are creating the institutional conflict; or 

• Increasing the independence in the decision-making for the university activity. 

Related Information

• Conflict of Interest and Commitment Policies 
• Gift Acceptance Policy 

Contacts