Conflict of Interest, Code of Ethics, Minority Business Enterprise Program

Procurement Manual
Section I

CONFLICT OF INTEREST

Individuals serving the University shall at all times act in a manner consistent with their fiduciary responsibilities to the University and shall exercise particular care that no detriment to the University results from conflicts between their interests and those of the University.

For the purposes of this statement, an individual is considered to have a conflict of interest when the individual, or any of his Family or Associates (i) has an existing or potential financial or other interest which impairs or might appear to impair the individual's independence of judgment in the discharge of responsibilities to the University, or (ii) may receive a material, financial or other benefit from knowledge of information confidential to the University. The "Family" of an individual includes his or her spouse, parents, siblings, children and, if living in the same household, other relatives. An "Associate" of an individual includes any person, trust, organization, or enterprise of, in or with which the individual or any member of his or her Family (i) is a director, officer, employee, member, partner, or trustee, or (ii) has a financial interest that enables him or her, acting alone or in conjunction with others, to exercise control or influence policy significantly, or (iii) has any other material association.

This policy is to be interpreted and applied in a manner that will best serve the interests of the University. If an individual believes that he or she may have a conflict of interest, the individual shall promptly and fully disclose the conflict to his or her supervisor and shall refrain from participating in any way in the matter to which the conflict relates until the conflict question has been resolved. In some cases, it may be determined that, after full disclosure to those concerned, the University's interests are best served by participation by the individual despite the conflict.

CODE OF ETHICS

Individuals purchasing goods and services on behalf of Harvard University should conduct business in a manner that is consistent with the educational and research goals of the University. Purchasing activities should be conducted in a professional manner. All qualified vendors should be given equal opportunity to compete for University business. Purchasing decisions should be made on reasonable assessments of quality, service, competitive pricing, and technical qualifications.

Efforts should be made to maintain positive and professional relations with vendors. Business should be conducted in good faith and disputes resolved quickly and equitably. Vendors doing business with the University should be held to standards promoting sound and ethical business practices.

Procurement decisions should be made with integrity and objectivity, free from any personal considerations or benefits.

MINORITY BUSINESS ENTERPRISE PROGRAM

Harvard University holds a unique position, not only in the academic, but in the world community, and has an enormous capacity to influence for the public good.

Historically, Harvard has championed the principle of Equal Opportunity. The University continues to make every effort to promote diversity throughout the student and employee populations, but recognizes that special efforts are needed to increase the level of participation by minority business enterprises (MBEs) in the University's procurement process. As members of the Harvard community with purchasing responsibilities, you should be accountable for creating a climate that encourages minority business enterprises to compete for University business and for eliminating any barriers that might impede their participation in University purchasing activities. The minority business community does not expect special considerations. It does expect equal access.

The Procurement Management Department supports Harvard's Minority Business Enterprise Program and your individual efforts by identifying qualified minority businesses and introducing these vendors to you. Procurement Management encourages you to communicate your successful experiences with minority businesses to other buyers around the University and to the Procurement Management Department. Procurement Management will work with you to develop meaningful and profitable relationships with the minority business community.

Buyers interested in learning more about the Minority Business Enterprise Program should contact the Manager of Strategic Procurement at 495-5401.