Conflict of Interest Policy

1.1 Conflict of Interest: A situation in which a person has a secondary interest (personal or professional) that could actually or be perceived to influence or impair their judgement, decisions or actions in the discharge of their primary duties or responsibilities to the University, in their role. These might be Financial Conflicts of Interests or Non-Financial Conflicts of Interest (as defined below).  

1.2 Minor Conflict of Interest: A set of circumstances that create a low potential for actual or perceived influence on decision making or discharge of duties. These conflicts can usually be managed by the individual and will in practice represent the majority of Conflicts of Interest. 

1.3 Major Conflict of Interest: A set of circumstances that create a high potential for actual or perceived influence on decision making, discharge of duties or which do or could constitute a reputational risk for the University or the individuals involved. Major conflicts must be declared, managed and a written note shared with an individual’s line manager. 

1.4 Financial Conflicts of Interest: where there is or appears to be opportunity for personal financial gain, financial gain to close relatives or friends. For example, holding shares in an external organisation that has a relationship with the University.  

1.5 Non-Financial Conflicts of Interest: where the commitments or obligations of an individual to a third party may mean the individual is unable to act in the best interests of both the University and the third party. For example, being appointed to the board of another organisation that has a relationship with the University.  

2.1 This policy applies to all individuals associated with the university, including staff, contractors, consultants, honorary and visiting appointees, as well as those involved in university governance, such as non-staff members of Senate and Council. 

2.2 Individuals are expected to identify, disclose and manage circumstances that might give rise to actual or perceived Conflicts of Interest. Critically, all those covered by the policy should, if in doubt, discuss or disclose and manage Conflicts of Interest as they arise. There is a strong presumption in favour of transparency. It is the individual’s responsibility to identify, disclose and manage their own conflicts.  

2.3 Besides this general expectation, all staff are specifically required to complete a 'Conflict of Interest Declaration' via My.HR promptly following an actual or perceived conflict of interest arising and will be prompted annually to affirm their understanding of and compliance with this Policy. 

3.1 The University is committed to conducting its affairs ethically and in compliance with legal and regulatory requirements. All members of our community must manage situations where personal, financial or other interests might conflict or appear to conflict with their duties and responsibilities or the best interests of the University and to declare and manage them. When avoidance of an actual or perceived Conflict of Interest is not possible, conflicts of interest require appropriate disclosure and management, to ensure fairness and transparency and to protect the individuals involved. If in doubt, those covered by the policy should disclose the Conflict of Interest and discuss with their manager how best to manage it.  

 4.1 Responsibilities for all. These responsibilities apply to all individuals associated with the University, regardless of their specific role or position: 

• • Proactively monitor, identify and disclose potential Conflicts of Interest on an ongoing basis. 

• • Manage and seek to mitigate minor conflicts of interest as they arise. If in doubt, declare.  

• • Formally declare major conflicts of interest as they arise and detail in writing, in conjunction with their line manager, approaches to managing a major conflict of interest. 

• • Promptly report suspected breaches of the Conflict of Interest policy. 

A failure to declare a Major Conflict of Interest promptly will be viewed as intentional, rather than inadvertent.  

4.2 Role-Specific Responsibilities. These additional responsibilities apply to specific roles within the university. These are in addition to the general responsibilities outlined above. 

4.3 It is important to note that a Non-Financial Conflict of Interest should not automatically be assumed to be a Minor Conflict of Interest. Similarly, a Financial Conflict of Interest will not automatically constitute a Major Conflict of Interest.  

4.4 If there is any doubt as to whether a Conflict of Interest exists, there is a strong presumption in favour of making a declaration and taking steps to manage the Conflict of interest, as if it existed. 

Compliance with this Policy is crucial for maintaining the integrity and reputation of the University. We have implemented various measures to support compliance, including monitoring mechanisms, procedures for reporting non-compliance and assurance audits. 

5.1 Monitoring Compliance 

Managers, Deans and Directors have responsibilities for monitoring compliance in their areas of responsibilities – both compliance with this policy and any agreed management plans for identified Conflicts of Interest. An annual check for compliance will be completed following the annual reminder being issued. 

5.2 Reporting Violations or Concerns 

Everyone associated with the University has a duty to report potential Conflicts of Interest, as well as any concerns about non-compliance with this policy, or any suspected unethical or improper conduct. Reports should be made following our Raising Concerns Process. 

5.3 Post Hoc Assurance 

Post hoc assurance checks will support compliance with the policy, by identifying gaps in compliance and understanding, the learning from which can be fed back in to improve the policy and supporting materials.  

5.4 Management Action 

Failure to comply with this policy or to operate within the supporting procedure and guidelines or failure to comply with any management plan for any Conflicts of Interest is a serious matter and may ultimately be considered under an appropriate disciplinary procedure. In serious cases, this may lead to the dismissal of employed staff.  

This policy will be reviewed every 3 years by the policy owner to ensure its continued relevance and effectiveness.