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
www.jhu.edu/news_info/policy/ethical.html.
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