Policy on Outside Professional Activities for Executives

 

Applicability

This policy applies to the president, vice presidents (including the provost), deans, and others whose compensation is subject to review by the Board of Trustees ("Designated Officials"); and administrators in positions designated under GW Human Resources classification streams E1 through E3, Senior Counsel, and those otherwise designated by the President or Chair of the Board (“Select Administrators”) (collectively “Executives”).

Policy Summary

The university requires Executives to disclose outside professional activities, so that those activities may be reviewed and, if necessary, managed. Executives shall obtain approval in advance before undertaking compensated outside professional activities, fiduciary obligations, and other outside professional activities that may reasonably be perceived as posing a conflict of interest or commitment.

Outside professional activities are not permitted if they will negatively affect the ability of an Executive to fulfill his or her responsibilities to the university, or impair or appear to impair independence or objective judgment in performing assigned duties.

This policy is a supplement to the Conflict of Interest for Non-Faculty Employees policy.

Policy

Reporting: Throughout the year, Executives shall report new outside professional activities to their supervisors. On an annual basis, Executives shall report previous fiscal year, anticipated, and ongoing outside professional activities through the annual Executive Conflict of Interest Questionnaire. In addition to facilitating compliance with university policy, the questionnaire also seeks information that is used by the university to complete the Internal Revenue Services Form 990.   

Outside professional activities should be reported if they provide compensation, or if they involve ownership or control of, fiduciary obligations to, or other leadership roles in, an outside entity. Any outside professional activities requiring advance approval, as discussed below, should also be reported.

Advance Approval: For the outside professional activities outlined below, Executives must seek and document advance approval as follows:

  • Designated Officials: from the supervising vice president or the president and then from the appropriate committee of the Board of Trustees.
  • Select Administrators: from their supervisor and the appropriate vice president in consultation with the Office of Ethics, Compliance, and Privacy.

The outside professional activities requiring advance approval are:

  • a position involving ownership or control of, or fiduciary obligations (i.e., founder, CEO, trustee, or director);
  • receipt of a single payment1 in excess of $2,500 per year for professional activities;
  • receipt of total payments in excess of $10,000 per year, from one or more sources, for professional activities;
  • any singular activity (paid or unpaid) that requires a time commitment of five or more days per fiscal year or may pose a conflict of interest. This includes any outside professional activities that may involve a significant time commitment during business hours or other obligations that may affect responsibilities to the university.
  • any outside professional activity after collectively exceeding twenty days of outside professional activities in a fiscal year

Review of Disclosures: Disclosures will be reviewed by the Office of Ethics, Compliance and Privacy and the Office of the Senior Vice President and General Counsel and may be shared with other university offices as appropriate, as well as with the Board of Trustees.

 


1 Within this policy, payment does not include royalties.

Forms

Advance Approval Form

Related Information

Conflict of Interest for Non-Faculty Employees Policy

Statement of Ethical Principles

Contacts

Contact Phone Number Email Address
Office of Ethics,  Compliance, and Privacy 202-994-3386 [email protected]
Office of the Senior Vice President and General Counsel 202-994-6503 [email protected]

Responsible University Official: AVP Ethics, Compliance, and Risk
Responsible Office: Office of Ethics, Compliance, and Privacy

Last Reviewed: March 10, 2020

 

Non-compliance with this policy can be reported through this website.