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Conflict of Interest Policy
The Office of the University CIO (UCIO) manages significant spending and valuable assets on behalf of the University as a whole as well as for the schools and affiliated institutions. In support of these important obligations of trust, it is essential that each employee perform his or her duties in a manner that will ensure no conflict between personal interests and those of Harvard University. UCIO subscribes to the broad principles outlined in the Policy Statement on Conflicts of Interest, adopted in 1975 by the Governing Boards for their own members and for the University's vice presidents, and deputy and assistant treasurers.
A conflict of interest exists when an individual's commitment to the University may be compromised by personal benefit. Every employee is expected to avoid situations or activities that could interfere with his or her unencumbered exercise of judgment in the best interest of Harvard University. In addition, it is considered inappropriate for any employee to make use of University property or other resources, including time, to advance personal interests and/or activities during the course of his or her employment at Harvard.
Most problems with conflict of interest or commitment can be prevented through prompt and thorough disclosure of the activity to UCIO senior management. It is the responsibility of all employees to disclose anything which may have the potential for a conflict of interest. All such disclosures shall be documented, and copies of the documentation will remain in the University's employment records.
It is the responsibility of UCIO senior management to evaluate all issues concerning potential conflicts of interest and to inform employees of this policy. If a potential conflict is disclosed, the employee(s) involved shall refrain from participation in the identified activity until the matter has been resolved.
All outside activities must be performed on the employee's personal and/or accrued vacation time. In no case are consulting activities or other outside pursuits permissible on University time, nor it is permissible to use University resources such as office equipment, supplies, or support staff in the course of outside consulting or personal business. These pursuits or personal activities must not divert the employee's attention from the University duties or consume so much time or creative energy that they interfere or appear to interfere with the employee's responsibilities to the University. This policy is not intended to limit reasonable participation in professional and community activities which benefit and reflect positively on the University, by mutual agreement of the employee and the supervisor.
For the purpose of this policy, vendors shall include present, former or potential suppliers of goods and services to the University and its affiliated institutions.
Employees should pay special attention to insuring they maintain the proper relationship between themselves and vendors of goods and services to the University. It is UCIO policy to discourage vendors from offering gifts of any kind to any employee or member of any employee's family. Such activity serves no useful business purpose, and can create conflicts of interest. It is recognized, however, that despite this policy, UCIO employees may occasionally be offered token gifts from suppliers as a gesture of good will and appreciation - often during the year-end holiday season. In such cases, the following guidelines shall apply to all employees:
- No employee (or family member of an employee) shall accept any gift of more than a token or nominal value ($100) from any supplier, under any circumstances. Acceptance of gifts with a value of less than $100 should be infrequent.
- Any meals or entertainment offered by a supplier shall be for bona fide business reasons, and shall not include travel or accommodation expenses. Employees attending meetings at supplier's facilities or conventions shall do so for business reasons at the expense of the University.
- On the rare occasion that an employee is asked to participate on Vendor Advisory Committee they may do so at the expense of the vendor with prior approval from their group Director.
- No employee (or family member of an employee) shall, under any circumstance, accept any offers of kickbacks, preferential treatment, or any form of favoritism from any suppliers. Should any employee become aware of any such offer, her or she shall immediately notify a member of UIS senior management.
If it is discovered that an employee has accepted a kickback, more than a token gift, or other favored treatment in violation of this policy, the employee will be subject to disciplinary action, up to and including termination of employment.
It is important that employees refrain from establishing employment or contractual relationships with any vendor eligible to provide the University with goods or services for a fee. Employees should not engage in any activities which are directly or indirectly competitive with the operations of UCIO. If UCIO employees provide consulting services or perform work outside of
Harvard on their own time, the work must not be performed for a vendor or potential vendor; it must not be competitive with the operations of UCIO; and in all instances the employee's managers or supervisor must be informed of the situation.
UCIO strongly discourages hiring family or household members of current UUCIO employees if they would be in the same work group. This policy applies to all positions (regular and temporary) unless extenuating circumstances caused by University guidelines, consolidation or displacement require an exception. All exceptions must be approved by the business unit manager and Human Resources.
UCIO employees may not negotiate with or establish a contractual relationship with a vendor on behalf of UCIO if the vendor is owned or managed by a family or household member or if a family or household member will be engaged in the delivery of the goods or services. If the potential for such a situation exists, it should be disclosed and wither the vendor should be eliminated from consideration of the UCIO employee should withdraw from the vendor selection process.
Any violation of these policies may lead to suspension of access and immediate review, with the possibility of revocation of privileges, or disciplinary action in accordance with Harvard University rules and procedures up to and including termination of employment.
Visit Harvard’s Conflicts Of Interest or Commitment Policy or contact UCIO, Human Resources at 495-1425.
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