COI Policies & Procedures
Yale University Policy on Conflict of Interest
In pursuit of its own mission, and consistent with the requirements of external agencies, particularly the federal government, Yale University has formulated the Policy on Conflict of Interest to identify and address potential, actual and apparent conflicts of interest and commitment. This policy is intended to increase the awareness of faculty, staff and students to the potential for conflicts of interest and commitment and to establish procedures whereby such conflicts may be avoided or properly managed.
Disclosure of External Activities and Financial Interests
All faculty members with University appointments of greater than 50%; all faculty who hold administrative positions; and all faculty and non–faculty personnel who are responsible for the design, conduct or reporting of research are required annually to submit a disclosure of their external activities and financial interests.
Yale Faculty Handbook
Section XX.E., “Outside Interests and Employment”, of Yale’s Faculty Handbook provides guidance about the amount of time that faculty members may devote to outside activities; it stipulates, for example, that a faculty member may not accept salaried employment at another institution while a full–time employee of Yale, that faculty may not spend more than one day in a seven–day work week on consulting activities, and that faculty ownership or management of private enterprises is subject to review and limitations. A link to the Faculty Handbook is available on the Provost’s Office website.
Purchasing Conflict of Interest (applies to faculty and staff)
According to Yale’s General Purchasing Policy 3201, a purchasing conflict of Interest exists when a Yale employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a supplier considered for a Yale purchasing transaction. Prior to purchasing or requesting goods or services from any entity in which you have a financial interest, contact Yale’s Purchasing Department for guidance, as additional disclosure requirements and certain restrictions may apply.
Staff Workplace Policies
Full–time non–faculty employees are expected to satisfy all of the requirements of their jobs, and should not permit outside activities to interfere with the performance of their Yale obligations. Some departments prohibit staff employees from consulting or engaging in other outside employment because of the likelihood of such interference. Other departments may permit certain outside activities, with appropriate notice to and written approval by the employee’s supervisor, so long as they do not interfere with employees’ Yale obligations. The Staff Workplace Policies set forth the University’s general expectations about staff and the avoidance of conflicts in performance of their duties.
Conflict of Interest Disclosure for Senior Administrators
Certain senior, non–faculty administrators designated by the President are also required to submit annual disclosures of outside activities and financial interests. These disclosures must be prepared on the Conflict of Interest Disclosure Form for Senior Administrators and submitted to the Office of the Vice President and General Counsel. The form will be provided to those administrators who are designated to submit them.