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Conflict of Interest Procedures

Conflict of Interest - Policies and rocedures
| Employees | Trustees |

For Employees:
The Policy Statement contains information regarding unacceptable activities, activities requiring prior approval, and terms and conditions of disclosure.

Annual Reporting
All employees must submit a disclosure report to their Department Chair, Adminstrative Manager, Vice President, or Executive Committee of the Board of Trustees, as appropriate, not later than January 31st for the previous year's activities even if there were none.
Advance Disclosure
Anticipated activities must be reported far enough in advance to allow time for inquiry and decision.
Determination of Conflict of Interest
Made by the appropriate Vice President who informs the affected employee in writing (with a copy to the Director) and informs all appropriate Institution offices
Conflict Resolution
Appeals are taken to the Director who has the ultimate authority to make a binding and final determination.


For Trustees:
A policy for conflict of interest disclosure by WHOI Trustees has been adopted by the Board of Trustees. Each Trustee and Officer (as defined by the Policy) is required to file a statement annually with the Clerk of WHOI on or prior to March 1. For more information on this subject click here.

Annual Disclosure
Forms and lists of vendors and investment managers will be provided by the Clerk's office to the appropriate trustees annually during January.
Other Disclosure
In the event a new disclosure becomes necessary, a form shall be filed as the information becomes known.

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