Conflicts of Interest or Commitment

Employees throughout the University have important fiduciary responsibilities in the work they perform. In support of these significant obligations, it is essential that employees perform their duties in a manner that will ensure no conflict, or any appearance of conflict, between their personal interests and those of Harvard University. To that end, the University subscribes to the broad principles outlined in the Policy Statement on Conflicts of Interest, adopted in 1975 by the Governing Boards for its own members and for the University's vice presidents, and deputy and assistant treasurers.

  1. Conflict of Interest
    A conflict of interest exists when individual commitment to the University may be compromised by personal benefit. Employees are expected to avoid situations or activities that could interfere with their unencumbered exercise of judgment in the best interests of Harvard University.

    In addition, it is considered inappropriate for employees to make use of University property or other resources, including time, to advance personal interests or activities during the course of their employment at Harvard.

  2. Conflict of Commitment
    This policy is not intended to limit reasonable participation in professional and community activities that benefit and reflect positively on the University, by mutual agreement of the employee and his or her supervisor. Paid outside activities that primarily advantage or benefit the employee are to be performed on the employee's personal time. In some circumstances, accrued vacation or personal time may be used to cover such absences.

    Paid personal consulting activities or other outside pursuits are not to occur on University time. It is not permissible to use University resources in the course of outside consulting or other pursuits. These resources may include, but are not limited to, office equipment, supplies or support staff. Such activities must not divert an employee's attention from his or her University duties or consume so much time or creative energy that they interfere, or appear to interfere, with an employee's responsibilities to the University.

  3. University Information
    The Technology Information Systems Policy provides guidance on avoiding conflicts with respect to the ownership and use of the University's information resources.

  4. Relationships with Third Parties
    Employees should pay special attention to ensuring they maintain the proper relationship between themselves and third parties with whom they come in contact in the course of performing their jobs for the University. These parties may include, but are not limited to, vendors of goods and services and potential students. Personal gain resulting from a relationship with a third party must be avoided. Such activity provides no useful business purpose and can create conflicts of interest.

  5. Disclosure and Resolution
    It is the responsibility of every employee to discuss with his or her supervisor, local human resource officer and/or department head any activity that might result in a conflict of interest or conflict of commitment before participating in that activity. The employee shall refrain from participation in the activity until it is determined whether a conflict of interest or commitment does exist and the matter is fully resolved. Resolution may include, for example, ceasing the activity, a change in job duties or a change in hours or salary. All disclosures and their resolutions shall be documented and copies of the documentation will remain in the individual's personnel records.

    Failure to disclose possible conflict of interest or commitment or refusal to cease activities that are determined to be in conflict with the University's best interests may be grounds for disciplinary action and may lead to termination.

For more information, please review the policy on the Provost’s website.

Last updated: 12/06/2007