Policy on Conflict of Interest
Policy Category: Executive
Effective Date: 9/26/2025
Responsible Officer: General Counsel
History: New Policy
Responsible Office: Compliance & Risk Management
Location: Link
Purpose
This policy is intended to provide guidance to Wentworth Institute of Technology (henceforth known as “the university” or “Wentworth”) related to Conflicts of Interest.
Scope/Applicability
This policy applies to all employees of Wentworth. Faculty who may be working on federally funded research projects are also responsible for applicable conflict of interest policies for their grant. Trustees are responsible for the provisions of the Conflict of Interest Policy in the bylaws.
Legal
- M.G.L. Ch. 180
- M.G.L. Ch. 180A
Policy
Wentworth Institute of Technology is committed to operating in an ethical manner and in compliance with applicable legal and regulatory requirements. Even the appearance of a conflict can be damaging to the reputation of Wentworth. All decisions by employees covered by this policy (described below) must be made solely in the best interests of Wentworth.
Wentworth recognizes that situations may on occasion arise where an employee’s private interests conflict with or appear to conflict with their obligations to Wentworth or the interests of Wentworth. This policy is intended to educate employees about situations that generate the potential for Conflicts of Interest; to clarify expectations about disclosing interests and activities that might result in Conflicts of Interest; and to identify means to manage, reduce, or eliminate such Conflicts of Interest.
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 Wentworth in dealing with an organization or individual having or seeking to have any business relationship with Wentworth.
A Wentworth employee shall be deemed to have a conflict of interest if:
- The individual is a trustee, director, partner, employee or agent of, or has a 5 percent or greater interest in, an entity involved in a transaction with or affecting Wentworth.
- The individual is aware that an immediate family member is an officer, trustee, director, partner, employee or agent of, or has a 5 percent or greater interest in, an entity involved in a transaction with or affecting Wentworth.
- Without regard to the previous statements, the individual’s duties to Wentworth are or might appear to be impaired by an existing or potential financial interest.
- The individual supervises or participates in a decision affecting a relative of the individual.
Definitions
Conflict of Interest: Means any circumstance in which the personal, professional, financial, or other interests of an employee may potentially or actually diverge from, or may be reasonably perceived as potentially or actually diverging from, their obligations to Wentworth and the interests of Wentworth. It includes indirect conflicts, such as benefits provided to an Immediate Family Member of an employee.
Immediate Family Member: Means spouse, parents, children, siblings or anyone living in the same household
Procedure(s)
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 his or her supervisor and refrain from acting unless written approval is received from the cognizant Vice President and the Vice President of Finance. The individual’s supervisor will coordinate this action.
Guidance for Avoidance of Conflict of Interest
All employees of Wentworth:
- 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, wholly free from the influence of personal consideration or relationship.
- Have a duty to Wentworth to negotiate 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.
- 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 Wentworth.
- Should not perform work or services, outside the course of their normal employment by Wentworth, for an organization doing or seeking to do business with Wentworth.
- Should devote their best efforts to the furtherance of Wentworth’s mission during the course of their employment. Outside employment or personal commitments which interfere with this are inappropriate.
Annual Disclosure
Depending on an employee’s position and responsibilities, an employee will be asked annually, to disclose situations that present actual or the appearance of a conflict of interest with their role at Wentworth.
Enforcement
Violations of this policy are subject to disciplinary action, up to and including termination of the employee’s association with Wentworth. This policy will not be enforced to the extent it is inconsistent with applicable law.
Additional Information & Related Documents
Interpretation & Revision
Any questions of interpretation regarding this policy shall be referred to the Director of Compliance and Risk Management or the General Counsel. They will be the final authority regarding the interpretation of this Policy.
This policy shall be reviewed every five years, however minor changes and updates can be made at any time.
Wentworth will typically apply the policy in place at the time it receives a report concerning the respected policy.
Additionally, in instances where two or more policies are implicated, a case-by-case determination will be made to determine what policy will be used.
Review and Revision History
This policy was drafted by representatives from the Office of the General Counsel. It was reviewed by Cabinet and approved by the President on 9/26/2025.