3.5 Policy on Conflict of Interest

The Institute's concern with conflict of interest has grown with the increasing complexity of our society, the variety of our relations with each other and with outside institutions, and a heightened national sensitivity to these issues. Some questions on conflict of interest arise from outside professional activities of the faculty and staff. Others, in the more traditional meaning of conflict of interest, derive from the opportunities an individual may have because of his or her position at the Institute to influence MIT's relationship with an outside organization in ways that would lead directly to the individual's personal financial gain.

In response to these concerns, the Institute has adopted the following statement of policy:

It is the policy of the Institute that its officers, faculty, staff, and others acting on its behalf have the obligation to avoid ethical, legal, financial, or other conflicts of interest and to ensure that their activities and interests do not conflict with their obligations to the Institute or its welfare. Essential to effective administration and adherence to this policy are: a) disclosure to designated Institute officers of outside activities and interests, including financial interests, which might give rise to conflicts, and b) readily available advice and counsel to individuals and to Institute department heads on any situation.

Accordingly, members and officers of the Corporation, Institute senior officers, and other members of the staff in a position to make decisions favoring one or another outside interest should annually acknowledge in writing their knowledge of this policy and either affirm that they have no interest, direct or indirect, in conflict with the Institute's interest, or identify any interests which have the potential for conflict. Members of the faculty should provide similar information to their department heads, as part of their annual report of their outside professional activities. Certain faculty and staff are subject to investigator disclosure requirements by federal agencies. In those cases, the specific policy should be obtained from the Director of the Office of Sponsored Programs or the Vice President for Research.

There are situations sufficiently complex that judgments may differ as to whether there is or may be a conflict of interest, and individuals may inadvertently place themselves in situations where conflict exists. Accordingly, anyone with a personal interest that may have the potential for conflict with the interests or welfare of the Institute should seek advice and guidance by reviewing the circumstances with the department head, center or laboratory director (who, in the case of sponsored research, should consult with the Director of the Office of Sponsored Programs), or such other person as may be designated by the President. The Faculty Committee on Outside Professional Activities is available for consultation in doubtful situations or those of unusual complexity.

Other potential conflicts of interest may arise in cases where an individual or individuals may have to influence or be influenced improperly by personal relationships, in ways that are not consistent with the education and employment policies and the principles to which the Institute is committed. Potential conflicts of interest of a particularly sensitive nature may arise out of sexual relationships, especially in the context of educational or employment supervision and evaluation. Because the effects on other people at work or in the classroom are frequently not apparent to the persons involved in a sexual relationship, anyone with such an involvement should be attentive to the feelings of colleagues and to the potential conflicts of interest that may be involved. (See also Section 1.5, Employment of Members of the Same Family.)

Members of the Institute community may choose to seek advice on these personal questions on a confidential basis from their department heads, the Human Resources department staff, the Medical Department staff, the Ombuds Office, or other counseling resources of the Institute. In addition to these resources, students also have available to assist them their faculty advisors, the faculty in residence, and the counseling resources of the Office of the Dean for Student Life and the Office of the Dean of Graduate Education. (See also Section 4.5, Outside Professional Activities in Policies & Procedures.)

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