A. Preamble

Despite the increasing frequency and complexity of the relationships of the University and its faculty and staff with industry, government and other entities, these relationships are governed by one basic principle: Employees of Georgetown University owe their primary professional responsibility to Georgetown University. To fulfill that responsibility they must be alert to the possibility that outside obligations, financial interests or employment relationships run the risk of compromising their objectivity as teachers, researchers, clinicians, and administrators. Acceptance of employment with the University entails a commitment to give one’s best efforts to this end and to assign first priority to the needs and goals of Georgetown.

At the same time, the unprecedented growth of academic research and other externally sponsored programs over the last several decades has generated significant opportunities for collaboration between faculty members and companies attempting to convert program findings into commercially viable products. Accepting assistance and financial support from for-profit enterprises makes possible research and other programs on a scope unachievable without that support, and fosters the University’s interest in serving society by making the benefits of its faculty members’ research and expertise available to those who need it most. A faculty member must, however, be on guard that his or her objectivity is not threatened by obligations owed to the companies or organizations that sponsor University programs.

In addition, members of the Georgetown University community whose work is supported by public funds incur a special obligation to preserve the public trust. The Federal Government requires assurance that faculty members are aware of potential conflicts of interest arising from interrelationships with Federal agencies and commercial sponsors and of their obligation to notify appropriate University officials of all outside activities that may have conflict of interest implications. Likewise, University officers and others acting on behalf of Georgetown University have an obligation to avoid conflicts, and the appearance of conflicts, between their financial interests and the interests of the University in dealing with any organization or individual having, or seeking to have, any business relationship with the University.

To further these goals and in compliance with applicable Federal policies, Georgetown University has developed a policy to identify and address potential, actual and apparent financial conflicts of interest. This Financial Conflicts of Interest Policy (the Policy) is designed to promote four fundamental objectives.

1. To heighten the awareness of faculty and staff to the potential for financial conflicts of interest, to identify conduct and situations that might constitute a conflict of interest, and to provide reliable and workable processes for disclosing, and eliminating or appropriately managing potential, actual and apparent conflicts of interest.
2. To ensure that relationships between faculty members and external sources of funding are structured in such a manner as to enhance the University’s mission in the areas of teaching and research.
3. To ensure that the relationship between faculty members and external sources of funding promotes values and practices essential to the pursuit of knowledge, including free and open communication among colleagues, the widest dissemination of research results through presentation at professional meetings and publication in professional journals, the encouragement of collaborative research, and the promotion of cordiality and mutual respect among researchers.
4. To ensure that University faculty and staff perform their responsibilities with objectivity and integrity and do not inappropriately benefit or appear to benefit personally, directly or indirectly, from an entity or person conducting or seeking to conduct business with the University.

The Policy applies to all employees of Georgetown University. It imposes initial disclosure requirements, however, only on (1) Faculty; (2) Staff who are responsible for (i) the procurement, exchange or sale of goods, services or other assets; (ii) the negotiation or formation of contracts or other commitments affecting the assets or interests of the University; (iii) the rendering of professional advice to the University; or (iv) managerial, supervisory or advisory functions related to the conduct of Sponsored Programs; and (3) Investigators. All other employees are obliged to make appropriate disclosure and follow the approval procedures required by the Policy if and when they are in situations that require disclosure and/or approval under the Policy. Additional requirements applicable to federally sponsored research and educational activities are set out in Appendices B and C. Questions about disclosure obligations or procedures should be addressed to the appropriate Conflict of Interest Officer or to the Office of University Counsel.

This Policy does not address a variety of other practical or ethical issues that may arise during the course of University employment, such as conflicts in time commitments, misconduct in scientific research, and other ethical issues, including those involving medical or scientific experimentation using human or animal subjects. Other University policies address these issues.