Officers, deans and all Washington University in St. Louis staff members (collectively referred to in this policy as employees) have a shared responsibility to ensure they conduct themselves in an unbiased manner and serve the mission of the university.

It is the responsibility of the university and its employees to guard against conflicts of interest that might compromise the integrity and objectivity of the university’s activities.

A conflict of interest exists if an employee’s position or authority may be used by the employee to influence or make decisions for the university that lead to any form of financial or other personal gain for that employee or for his/her family. Outside professional activities also have the potential to create conflicts of interest and should be periodically examined to ensure they are fully consistent with the highest duty of loyalty owed to the university.

Procedures

I. Members of University Council and other employees who report directly to the chancellor shall certify the Code of Conduct and disclose their outside activities and financial interests annually to the chancellor and otherwise upon his/her request. This includes annually submitting completed questionnaires in substantially the form attached to this policy, as the same may be revised by the chancellor from time to time.

Disclosure Review

The chancellor will review the disclosures and, with the advice of the executive vice chancellor and general counsel, determine whether the activity or interest disclosed will compromise, or reasonably appear to compromise, the individual’s actions or decisions on behalf of the university. If so, strategies shall be developed to manage or eliminate the conflicts of interest. The chancellor shall annually update the chairman of the Board of Trustees regarding any material conflicts disclosed and how they were managed.

Certification of “Downstream” Conflict of Interest Review

Members of the University Council and all other employees who report directly to the chancellor shall certify to the chancellor annually, and otherwise upon his/her request, that they have assumed responsibility for managing the appearance or reality of conflicts of interest or conflicts of commitment for those reporting to them, to the extent that other institutional mechanisms for disclosure and management of COis (e.g., research, clinical or procurement conflicts of interest) do not fully apply.

II. The chancellor shall similarly certify the code of conduct and disclose his/her outside activities and financial interests annually to the chairman of the Board, who will review them and, with the advice of the executive vice chancellor and general counsel, determine whether any of the activities or interests disclosed compromise, or reasonably appear to compromise, his/her actions or decisions on behalf of the university. If so, the chairman of the Board will develop strategies to manage or eliminate the conflicts of interest.

Policy Noncompliance

Employees who fail to disclose significant outside activities or financial interests or who fail to implement the conflict of interest management strategies issued to them will be subject to disciplinary action appropriate for the severity of the matter.

Relationship to Other University Policies

Disclosures required by the above policy do not relieve an individual’s obligation to disclose activities and financial interests potentially creating conflicts of commitment or conflicts of interest in connection with their research, clinical care and procurement responsibilities, among others.

Links to those policies:

Interpretation

Questions concerning interpretation of this Conflict of Interest Policy should be directed to
the university’s executive director of compliance and audit at 314-362-4915.