Conflict of Interest

Institute Officers & Department Heads

Introduction

One of the primary responsibilities of the officers and employees of Wentworth Institute of Technology is to safeguard the tangible and intangible assets of the institute. In this regard, adequate systems of internal controls must be adapted and implemented to ensure that the Institute's mission and objectives are not compromised. The following conflict of interest policy has been developed as part of an overall system of internal controls.

Summary

It has been and shall continue to be the policy of Wentworth Institute of Technology that all officers and employees avoid any conflict, or appearance of conflict, between their personal interest and the interest of the Institute in dealing with any organization or individual having or seeking to have, any business relationship with the Institute.

Definition

An Institute officer or employee shall be deemed to have a Conflict of interest if:

  1. The Individual is an officer, trustee, director, partner, employee or agent of , or has a 5% or greater interest in, an entity involved in a transaction with or affecting the Institute; or
  2. The individual is aware that a member of his or her family (spouses, parents, children, siblings or anyone living in the same household) is an officer, trustee, director, partner, employee or agent of, or has a 5% or greater interest in an entity involved in a transaction with or affecting the Institute; or
  3. Without regard to (A) or (B) above, the individual is or might appear to be impaired by an existing or potential financial interest; or
  4. The individual supervises or participates in a decision affecting a relative of the individual.

Guidance for Avoidance of Conflict of Interest

All employees of the Institute:

  1. Are charged with fidelity in the performance of their duties and should conduct themselves in such regard solely for the purpose, benefit, and interest of Wentworth Institute, wholly free from the influence of personal consideration or relationship.
  2. Have a duty to negotiate for the Institute with third parties, to make recommendations with respect to such negotiations, or to pass judgment on such negotiations, wholly free from the influence of any personal considerations.
  3. Should not accept for themselves, or the benefit of any relative or friend, any payments, loans, services, favors involving more than the ordinary social amenity, or gifts of more than token value from any person or organization doing or seeking to do business with the Institute.
  4. Should not perform work or services, outside the course of their normal employment by the Institute, for an organization doing or seeking to do business with the Institute.
  5. Should devote their best efforts to the furtherance of the Institute's mission during the course of their employment. Outside employment or personal commitments which interfere with this objective are inappropriate.

Compliance

Before any action is taken by an individual on behalf of Wentworth where an actual or potential conflict of interest may exist, the individual will promptly make full disclosure to their supervisor and refrain from acting unless written approval is received from the cognizant Vice President and the Vice President of Business & Finance. The individual's supervisor will coordinate this action.