1.0 Policy Purpose
This policy sets forth Brown’s approach to identifying, evaluating, managing, and eliminating actual and potential Institutional Conflicts of Interest (ICOIs).
2.0 To Whom the Policy Applies
This policy applies to Brown University, as an institution and acting through its Institutional Officials.
3.0 Policy Statement
All decisions made and actions taken by Brown University must support the best interests of the University. ICOIs have the potential to affect the University's pursuit of its mission, the integrity of its research, and its reputation.
The University is committed to avoiding, eliminating, or managing actual, potential, and perceived ICOIs in order to, and in a way that promotes and protects the University’s interests, including its interests in advancing its mission, conducting research with integrity, and maintaining public trust. Many potential ICOIs are avoided, mitigated, or managed as a result of or through other University policies. (Examples of these policies are noted in Section 7.0.) This policy does not impact or change those policies.
3.1 Identifying ICOIs
An ICOI is a set of circumstances that creates a risk that the decisions or actions of the University regarding a University interest, decision, or activity will be unduly influenced by a secondary interest of the University or its Institutional Officials.
Examples of situations that may present actual, potential, or perceived ICOIs include the following:
- An Institutional Official with an interest in a business entity is in a position to act on behalf of or make decisions for the University in a way that may benefit or be perceived to benefit the business entity.
- The University licenses University-owned intellectual property (IP) to a company, and receives royalties from and has an equity interest in the company. The company also sponsors research at the University, and the research focuses on advancing the IP and preparing it for market.
3.2 Addressing ICOIs
The University has established an ICOI Committee. The ICOI Committee members are appointed by the President. The ICOI Committee reviews and evaluates actual, potential, or perceived ICOIs on an annual basis and as otherwise needed or warranted by the circumstances, including when new or updated information is disclosed to and/or received by the University. When new or updated information is disclosed or received, the ICOI Committee must review and evaluate the circumstances as soon as practicable. This review and evaluation is governed by related procedures.
After the ICOI Committee’s review and evaluation, if it determines that an actual, potential, or perceived ICOI may exist, the ICOI Committee will make a recommendation to the President or the President’s designee, or, with regard to members of the Corporation and members of the Standing Committees of the Corporation, to the Chancellor and the President, regarding how to address that actual, potential, or perceived ICOI. The Chancellor, President or the President’s designee will review the Committee’s assessment and recommendations, and determine whether and how to address, mitigate, or eliminate the identified actual, potential, or perceived ICOI.
If addressed as a result of another University policy, a potential, actual, or perceived ICOI need not, though may, be reviewed by the ICOI Committee under this policy and related procedures.
4.0 Definitions
For the purpose of this policy, the terms below have the following definitions:
Institutional Conflict of Interest: An ICOI is a set of circumstances that creates a risk that the decision or action of the University, regarding a University interest, decision, or activity will be unduly influenced by a secondary interest of the University or its Institutional Officials.
Institutional Official: Institutional Officials are members of the Corporation, members of the Standing Committees of the Corporation, members of the President’s Cabinet, and other individuals the President determines are Institutional Officials for the purposes of this policy.
Research: For the purpose of this Policy, research includes but is not limited to, basic and applied research, clinical research, research fellowships and training programs, and research-related activities in undergraduate, graduate, and medical education.
5.0 Responsibilities
All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure compliance with it.
6.0 Consequences for Violating this Policy
Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures and rules (e.g., Corporation rules).
7.0 Related Information
Brown University is a community in which employees are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).
The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws, and requirements.
7.1 Related Policies:
7.2 Related Procedures
7.3 Related Forms
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7.4 Frequently Asked Questions (FAQs)
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7.5 Other Related Information
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Policy Owner and Contact(s)
Policy Owner: President
Policy Approved by: The Corporation of Brown University
Contact Information:
Policy History
Policy Issue Date:
Policy Effective Date:
Policy Update/Review Summary:
Broadens the scope of the Policy for Institutional Conflicts of Interest in Research. Previous policy version(s) superseded by this policy:
- Brown University Policy for Institutional Conflicts of Interest in Research, Effective Date: February 11, 2012
Webpage updated on November 22, 2023