Conflict of Interest Policy

Decisions should serve the Institute, not private interests.

The JR Institute is committed to identifying, disclosing, reviewing, and managing conflicts that could affect institutional judgment, public trust, research integrity, or charitable resources.

Governance Framework

This page describes the Institute’s planned public standard. A formal annual disclosure process and board-approved policy should be adopted before active financial and research operations.

Policy Purpose

A conflict is not automatically wrongdoing. Hiding it creates the greater risk.

People may have financial, family, professional, political, academic, or organizational relationships that overlap with Institute responsibilities.

The purpose of disclosure is to let independent decision-makers determine whether the interest is harmless, manageable, requires recusal, or makes the transaction inappropriate.

Common Conflict Areas

Conflicts may arise in finance, research, employment, and partnerships.

01

Financial Interests

Ownership, investment, compensation, debt, commissions, gifts, or other financial benefit connected to a decision.

02

Family & Personal Relationships

Decisions involving relatives, household members, close personal relationships, or people with significant personal ties.

03

Outside Organizations

Leadership, employment, consulting, ownership, board service, or fiduciary duties owed to another organization.

04

Research Conflicts

Sponsor influence, intellectual property, publication pressure, personal advocacy, or financial interests affecting research judgment.

05

Procurement & Vendors

Selecting, supervising, paying, or negotiating with a vendor connected to an interested person.

06

Gifts & Influence

Gifts, travel, hospitality, discounts, favors, or benefits that could influence or appear to influence judgment.

Who Is Covered

This policy is intended to apply to trustees, officers, employees, researchers, fellows, volunteers, contractors, committee members, and others with authority to influence Institute decisions or resources.

What Constitutes a Conflict

A conflict of interest exists when a person’s outside interest could reasonably affect, or appear to affect, impartial judgment on behalf of the Institute.

A potential conflict may exist even when no improper action has occurred. Apparent conflicts matter because they can weaken trust and create uncertainty about whether a decision was independent.

Duty to Disclose

Covered persons should disclose relevant interests promptly, before participating in discussion, recommendation, approval, supervision, payment, or evaluation.

  • Describe the relationship or interest
  • Identify the transaction, project, person, or organization involved
  • Explain any potential financial or personal benefit
  • Provide enough information for independent review
  • Update the disclosure if circumstances change

Recusal and Participation Limits

A person with a material conflict should not use their position to influence the outcome and may be required to leave the discussion, abstain from voting, avoid access to confidential evaluation material, or transfer supervisory responsibility.

The minutes or decision record should document the disclosure, absence or abstention, independent review, and final determination.

Independent Review

Disinterested trustees or authorized reviewers should determine whether a conflict exists and whether it can be managed.

Reviewers may consider necessity, fairness, comparability, alternatives, market value, mission benefit, legal risk, private benefit, and the appearance of impropriety.

Related-Party Transactions

Transactions involving trustees, officers, key employees, family members, controlled entities, or other related parties require heightened review.

  • Confirm the transaction advances the Institute’s mission
  • Determine whether better alternatives are reasonably available
  • Obtain independent pricing or valuation where appropriate
  • Ensure terms are fair and reasonable to the Institute
  • Document approval by disinterested decision-makers

Gifts, Travel, Hospitality, and Benefits

Gifts or benefits should not be accepted when they could influence, reward, or create the appearance of influence over Institute decisions.

Modest, ordinary, and mission-related hospitality may be acceptable when lawful, infrequent, transparent, and not tied to a pending decision.

Annual Disclosure Process

Trustees, officers, key employees, and designated personnel should complete periodic conflict disclosures and certify that they understand the policy.

Annual disclosure does not replace the duty to report a new conflict when it arises.

Failure to Disclose or Follow the Policy

Failure to disclose a material conflict, improper participation, retaliation, false disclosure, or misuse of confidential information may result in corrective action.

Possible responses include additional review, rescission or revision of a transaction, removal from a decision, repayment, discipline, termination, board action, or legal referral.

Framework date: July 2026

Review Process

Disclose first, review independently, and document the decision.

  • Identify the interest. Describe the financial, personal, professional, or organizational connection.
  • Pause participation. The interested person should avoid influencing the review.
  • Evaluate alternatives. Compare independent options, pricing, qualifications, and mission value.
  • Decide through disinterested authority. Only unconflicted reviewers should approve or reject the matter.
  • Record the outcome. Preserve disclosures, recusals, supporting evidence, and the final decision.
Disclose a Conflict

Report the relationship before the Institute makes the decision.

Use the contact process for potential conflicts, related-party transactions, vendor concerns, research interests, gifts, or recusal questions.

Submit a Conflict Disclosure

Identify the person, organization, decision, financial or personal interest, and any deadline involved.

Contact the Institute