22.1 Policy

 In addition to their duties as faculty, academic and administrative staff, and the University Officers and other Senior Level Executives(collectively referred to as “employees” in this chapter) of OIST Graduate University (hereinafter “the University”) often serve on external committees, commissions, panels, and boards of directors.  The more entrepreneurial among them engage in private consulting or other business activity.  University employees also support a variety of social, community, and political causes.  Moreover, in the course of their official duties, employees develop relationships with vendors, research sponsors, donors, and others who contribute to or support the University.

It is the policy of the University to encourage all of these endeavors and relationships.  However, care must be taken to ensure that none gives rise to conflicts of commitment or interest. The matters covered in this policy are of great importance to the University.  Each member of the University community has a responsibility to avoid and prevent conflicts of interest and to take steps to avoid even the appearance of impropriety.

Responsibility for review and ultimate resolution of conflict of interest matters is vested in the Chief Operating Officer (hereinafter “COO); a four-person panel, comprised of University General Counsel, Chief Compliance Officer (hereinafter "CCO"), and two faculty members appointed by the Dean of Faculty Affairs (known as the “Conflict of Interest Review Panel”) will assess the facts and report their findings and recommendation to the COO for decision.  As a general rule, conflicts of interest determinations are based on what potential outcomes are made possible by the situation, rather than on the character, intent, or actions of the employee.  However, a finding that an employee willfully ignored or intentionally violated the policies and rules of Chapter 22 requires that the employee be subjected to disciplinary action including significant sanction or possible termination of employment.  See also Misconduct & Whistleblower Protection .

 The following policies (and related rules and procedures) should guide all University employees as they carry out their work at the University. 

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