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The newspaper of The Johns Hopkins University November 5, 2007 | Vol. 37 No. 10
Brody Ethics Letter Focuses on Conflict-of-Interest Policies

By Greg Rienzi
The Gazette

In a letter accompanying the release of the university's 2007 Statement of Ethical Standards, President William R. Brody stressed the importance of adhering to the university's conflict-of- interest policies.

Of note, the letter includes reference to a new policy, now in draft form, of institutional conflicts of interest.

The policy states that the financial interests of the university, and of its institutional officials, must not compromise the integrity of research or unduly influence decisions at Johns Hopkins. It calls for each division to appoint a committee that reviews high-level potential institutional conflict of interests.

Institutional financial interests may be created by gifts, payments, royalty income, equity or other benefits from for-profit organizations. A potential conflict of interest could arise, for example, when the university holds stock in a company to which it has licensed technology, and then a faculty member wants to conduct clinical research to test that technology.

The policy, which will be phased in, applies to all university divisions, institutes, centers and units, and to the Johns Hopkins Health System and all its constituent entities.

Julie Gottlieb, who staffed the committee that developed the policy on institutional conflict of interest, said that many details need to be worked out and considered before the new guidelines are fully implemented.

"It's intellectually complex, but we realize there are real risks. Even the appearance of an institutional conflict of interest is something we have to pay attention to," said Gottlieb, assistant dean for policy coordination at the School of Medicine. "To have a credible policy, we have to know what arrangements are out there that may present risks. We have to address the highest risk areas — such as human subject research — first, and then move methodically toward implementing other aspects of the policy."

The adoption of an institutional conflict-of-interest policy, which had already been under serious consideration by university officials, was a recommendation of an external committee appointed by President Brody in 2006. The committee's charge was to review current conflict-of- interest policies and make recommendations concerning possible institutional conflicts of interest in connection with contracts between the university and private businesses.

Brody asked the committee to propose a road map for an effective process for evaluating proposed relationships, including recommended procedures for identifying and resolving issues.

The university wanted to ensure that the institution's decisions on critical matters are made objectively and without bias, as opposed to perceived financial benefit.

"Johns Hopkins was founded for the betterment of human life and is funded largely through philanthropy and public support. Everything we do rests on our reputation for integrity," Brody said in a broadcast letter concerning the ethics statement's release. "We all, therefore, have a responsibility to conduct ourselves and the university's business in an ethical manner."

The university's Statement of Ethical Standards, which is issued annually, guides the professional conduct of all Johns Hopkins administrators, faculty and staff. The statement requires compliance with all applicable federal, state and local laws, as well as university policies.

Brody's letter also refers to the university's individual conflict-of-interest policy.

In a recent high-profile case, the university learned that Student Loan Xpress had paid about $65,000 in tuition for or consulting fees to the director of one of Johns Hopkins' seven financial aid offices. The payments, made from 2002 to 2006, had never been disclosed to Johns Hopkins, a violation of the university's conflict-of-interest policies.

The university's investigation — including interviews and an extensive review of documents — found no evidence that any university official was aware of the consulting and tuition payments from the loan company.

In the broadcast letter, President Brody reminded all employees to disclose and obtain approval from a supervisor whenever his or her relationship to an outside party might appear to influence the conduct of university business.

Brody called attention to the university's policy on the acceptance of gifts, which states that employees may not accept gifts and entertainment that might influence a decision or compromise judgment. Employees cannot accept any gift or benefit whose value exceeds $100 from an existing or potential vendor where the employee has authority or influence over university business decisions affecting the vendor.

Several university divisions and units have additional conflict-of-interest policies that apply to their activities.

To view the entire ethics statement, go to


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