Conflict of Interest and Disclosure Policies
1) Purpose: To maintain its independence, impartiality, and credibility, CAPI must act without regard to the private interests of its advisory board members and Staff.
2) Definitions:
a. “CAPI” is the Center for the Advancement of Public Integrity at Columbia Law School.
b. “Private Interests” are pecuniary interests, personal affiliations and associations, and family interests through which a person may derive substantial benefit.
c. “Staff” includes CAPI’s permanent and contingent officers and volunteers, including fellows, interns, and contractors, but not advisory board members.
d. “University” is Columbia University in the City of New York.
3) Duties of Disclosure:
a. CAPI Staff have an affirmative duty to disclose any relevant Private Interests to the executive director whenever a situation arises in which such interests may cast doubt or even the appearance of doubt on their ability to serve CAPI impartially. Examples of CAPI actions likely to occasion such disclosures include financial transactions, hiring decisions, and public activities or publications that may imply the endorsement of a political candidate or a for-profit entity.
b. The executive director has an affirmative duty to disclose Private Interests, as outlined above, to the advisory board chair.
c. CAPI Staff who are University employees must act in compliance with the University Policy on Conflict of Interest.
d. Although members of the advisory board serve in a purely advisory capacity, they should disclose to the advisory board chair and to the executive director any Private Interests that may cast doubt or even the appearance of doubt on their ability to serve CAPI impartially by providing advice or participating in CAPI activities. Affected members should excuse themselves from relevant advisory board discussions or other CAPI activities, and may be asked to do so by the advisory board chair.
e. The executive director should make appropriate inquiries if he or she has reason to suspect a member of the Staff or advisory board member has failed to disclose a potential conflict of interest.
4) CAPI Events: Members of the advisory board with Private Interests in for-profit entities, and other representatives of such entities, may make presentations at CAPI events or author CAPI publications only if their participation is distinct from their relationships to such entities and does not appear to imply CAPI’s endorsement of such entities.
5) Disclosure of Donations: CAPI welcomes monetary or in-kind donations, including from Staff and advisory board members. CAPI will disclose the donations it receives in its annual report and will disclose on its website all donations of $1,000 or more. However, CAPI may accept anonymous donations in compliance with University policies.