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Brookings Policies on Independence and Integrity

The Brookings Institution is a nonprofit organization devoted to independent, in-depth research that leads to pragmatic and innovative ideas on how to solve problems facing society.

The integrity and objectivity of Brookings scholars and their research constitute the Institution’s principal assets. Our policies, summarized here, reflect these values. (Links to the policies can be found below.)

Brookings’s commitment to institutional independence is rooted in the individual independence of its scholars. Therefore, the Institution does not take positions on issues. Its scholars’ obligation to the Institution is to meet the highest standard of research, uphold their own reputations for sound professional ethics, and develop recommendations that are relevant and actionable. The Institution’s obligation to them is to respect and protect academic freedom, provide a workplace that is supportive and inclusive, and help them amplify the impact of their research and policy recommendations.

It is in that spirit that Brookings scholars testify before Congress, interact with government officials in the United States and abroad, inform the media and the citizenry, and join with the nonprofit, private and public sectors on projects that benefit society. We strive to set an example of nonpartisanship and civil discourse, using Brookings’s convening power to provide a platform for discussing the most pressing issues of the day. We believe in promoting collaborative efforts to advance the public good through working with other think tanks, foundations, universities, and the private sector, as well as government officials.

Our relationships with these and other entities and individuals are based on their roles as stakeholders in the management of an increasingly complex and interconnected world. Our association with them is subject to clear and specific guidelines that ensure compatibility with our mission and values. In all cases, Brookings and its scholars reserve authority and responsibility for deciding on areas of activity, methodology, conclusions, and presentation.

Brookings is financed through the support of a diverse array of foundations, corporations, governments, and individuals, as well as an endowment. These funding sources are listed in the Institution’s Annual Reports.

The Board of Trustees has fiduciary responsibility for the Institution. Brookings is led by a management team (the Steering Committee) comprising the president, who reports to and serves at the pleasure of the Board, and an executive vice president, along with the vice presidents of the research programs and non-research programs, and general counsel. This team works to ensure that Brookings is operating efficiently and adhering to its values: quality, independence, and impact.

Research Independence

Brookings has adopted policies that enshrine the requirement that its personnel not permit the interests of any outside party to inappropriately influence Brookings’s work, including its research methods or conclusions.

The Institution and its personnel, including its scholars, may not engage in activities that constitute lobbying; require Brookings to register as a foreign agent under the Foreign Agents Registration Act; or that might otherwise call into question the independence and objectivity of the Institution’s research.

While Brookings personnel regularly engage with outside parties, including subject matter experts, stakeholders, government officials, and the general public, Brookings scholars ultimately have the final word on their research and other activities. This does not preclude Brookings personnel from expressing policy views that happen to align with the views shared by an outside party, provided such views are not the result of inappropriate external influence.

In addition, Brookings has established a set of donor guidelines that govern its fundraising and donor engagement activities. As part of this, Brookings will not accept gifts that seek to inappropriately influence the Institution’s work.

Conflicts of Interest

Brookings has an extensive Conflict of Interest Policy, which all employees and affiliates—both resident and nonresident must abide by. Brookings’s Conflict of Interest Policy sets forth the Institution’s guidelines and procedures for identifying, resolving, or managing real, potential, or perceived conflicts of interest that may arise. Any effort to influence the Institution’s work, or direct its resources, or any relationship that might cause a reasonable, objective reader to question the objectivity of the Institution’s work could present a conflict of interest or the appearance of a conflict of interest and should be disclosed and resolved in accordance with the Policy.

Read our full conflict of interest policy

Read our summary of rules on conflict of interest for resident scholars

Read our summary of rules on conflict of interest for nonresident scholars

In addition to our policy governing employees and affiliates, we have a Conflict of Interest Disclosure Policy for Outside Contributors, which requires disclosure of relevant interests and relationship by outside contributors to Brookings publications (non-employee, unaffiliated authors). Relevant disclosures will be made available to the public on the piece of content posted or published. If there is nothing to disclose, this too will be explicitly stated on the piece of content.

Read our conflict of interest disclosure policy for outside contributors

Nonpartisanship

Consistent with the Brookings Institution’s mission, Brookings scholars may provide nonpartisan public policy analysis and recommendations to public officials and candidates for public office. In accordance with the Institution’s commitment to nonpartisanship, Brookings personnel may not participate in partisan political activity on behalf of the Institution. Brookings personnel must also take appropriate steps to avoid conflicts or confusion between their outside political activities and their Brookings affiliations, including by obtaining the Institution’s approval and publicly disclosing their activities, as necessary.

Read our full nonpartisanship policy

Plagiarism and Research Misconduct Policy

Brookings is committed to maintaining the highest integrity in its independent research and other activities. As such, the Institution prohibits Brookings personnel from engaging in research misconduct, including plagiarizing, fabricating, or misrepresenting their research as well as failing to comply with applicable law or ethical standards. This applies to research misconduct in connection with a Brookings work and may also apply outside work written by an individual associate with Brookings.

Reporting, Investigations, and Whistleblower Policy

Brookings is committed to conducting its business in a lawful and ethical manner. Brookings has outlined the process for reporting and investigating suspected violations of Brookings policies or other misconduct in the course of Brookings business, including illegal or unethical activities.

Individuals should report suspected misconduct to a Brookings supervisor or Human Resources business partner. For significant suspected misconduct, individuals may report the matter to a Brookings Vice President, the Vice President and Chief Human Resources Officer, the Vice President and General Counsel, or the Executive Vice President.

Individuals may also report misconduct anonymously:

Brookings will undertake a prompt investigation as may be appropriate under the circumstances. Brookings ensures that individuals reporting suspected violations in good faith, or participating in related investigations, will not face retaliation.

Anti-Bribery and Compliance with Laws

Brookings is committed to conducting business legally and ethically. Toward this end, Brookings will conduct every international business transaction with integrity and will comply with the laws and regulations of the United States, particularly the provisions of the Foreign Corrupt Practices Act (“FCPA”), the anti-boycott laws, and the Office of Foreign Assets Control’s (“OFAC”) country embargoes. Additionally, Brookings will comply with the U.K. Bribery Act of 2010 (“UKBA”). Brookings will also comply with the laws and regulations of each foreign country in which it operates. In brief, Brookings’s policy is that all employees, affiliates, and contractors are prohibited from giving or offering to give anything of value to anyone to influence the individual to obtain an improper advantage. Moreover, all employees, affiliates, and contractors are prohibited from receiving anything of value if there is apparent intent to influence for an improper advantage. Additionally, Brookings employees, affiliates, and contractors may not provide anything of value to any person if the Brookings employee, affiliate, or contractor knows or believes that there is a significant risk the recipient will give some or all of the payment or gift to someone to influence for an improper advantage.

Anti-Terrorism Due Diligence

Brookings has an Anti-Terrorism Due Diligence Policy to reduce the risk of inadvertently engaging in transactions with prohibited individuals or organizations. The policy requires Brookings personnel to cross-check and verify the identity of donors, applicants for employment, and individuals and entities with whom the Institution transacts business. The policy requires Brookings to undertake due diligence according to the procedure delineated in the policy and to document the fact that they have done so.

Brookings retains the right to revise, replace, or supplement its policies. We are constantly reviewing our internal policies and procedures to ensure that we consistently safeguard our independence. The posting of these policies is for information purposes only, and nothing in these policies creates any legal or contractual rights or duties. If you have questions about any policy or procedure, please contact the Office of Communications at 202-797-6105.

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