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 managing director, 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 a Research Independence Policy that enshrines in a single document the requirement that its scholars be independent and act accordingly. Specifically, the Institution and its personnel, including all scholars, may not engage in activities—on behalf of Brookings or others—that run afoul of the IRS prohibition on a substantial part of the Institution’s activity constituting attempts to influence legislation; that would require registration under the Lobbying Disclosure Act, the Foreign Agents Registration Act, or state and local lobbying disclosure laws; or that might otherwise call into question the independence and objectivity of the Institution’s research. As part of this commitment to safeguarding independence, Brookings has established a set of Donor Guidelines that govern all fundraising and donor engagement activities by resident and non-resident scholars, development officers, and other staff. Brookings will not accept gifts from donors who seek to undermine the independence of its scholars’ research or otherwise to predetermine or influence recommendations. Brookings does not conduct proprietary research.

Brookings scholars and other personnel must not permit the interests of any third party—whether a political party, government (foreign or domestic), donor, or non-governmental organization—to adversely influence their methods or conclusions. Brookings scholars may seek input from a number of interested stakeholders but they ultimately have the final word on their research and other activities. If a scholar believes he or she is being inappropriately pressured regarding the analysis, conclusions, or output of a research product or other activities, the scholar should inform the research program Vice President, the Institution’s Executive Vice President, or any other member of the Management Team. When engaging in scholarly activities on behalf of Brookings, its scholars must not act as representatives, lobbyists, advocates, or agents of any third party. This must remain the case regardless of the extent to which a scholar’s views coincide with those of a third party.

Read our full research independence policy

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

Nonpartisanship

To protect the Brookings Institution’s commitment to nonpartisanship, Brookings personnel may not use the Institution’s resources—including support staff time, email accounts, computers and phones, or Brookings’s premises—for political activity. Consistent with the Institution’s mission, Brookings scholars may provide analysis and recommendations on matters of public policy on a nonpartisan, non-exclusive basis to public officials and candidates for public office. However, if staff members advise candidates, political campaigns, or political organizations such as political action committees or party campaign committees, in any private circumstance that constitutes or connotes exclusive support, they must do so in a personal capacity, outside regular business hours. They must make clear that they are acting as individuals and not on behalf of Brookings. They must refrain from representing or counseling candidates at public events or media appearances, and they should not use their Brookings affiliation in any public communications with, or on behalf of, a campaign or candidate. Brookings personnel must request leave without pay if they wish to serve as a surrogate or counsel candidates at public events or media appearances, or if their political activities interfere with or take time away from their Brookings obligations. Members of the Steering Committee shall not affiliate with any campaign, provide exclusive analysis to any candidate, even outside official hours, or make personal endorsements of candidates.

Read our full nonpartisanship policy

Policy on Integrity of Research

Our policy on Integrity of Research establishes the Brookings Institution’s commitment to independent, non-partisan research and publication, and to maintaining the highest integrity in pursuit of its mission. It also sets forth procedures the Institution has implemented toward achievement of this goal. The Policy prohibits research misconduct, which is defined as intentional or knowing fabrication, misrepresentation, or plagiarism in proposing, performing, reviewing research, or in reporting research results. Research misconduct does not include honest errors or differences of opinion. Research misconduct includes failure to comply with requirements for the protection of human and animal research subjects.

An individual should report observed or suspected research misconduct to any one or more of the following officers: Executive Vice President; Vice President and General Counsel; Vice President and Chief Financial Officer; Vice President and Chief Operating Officer; or any research Vice President.

In addition, an individual may report research misconduct using the procedures set forth in the Institution’s Whistleblower Policy. The Institution’s Whistleblower Policy includes two mechanisms for reporting allegations anonymously:

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.

(last updated: January 2016)