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Governance and Compliance Division

 

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Summary plus links to the Policy and associated FAQs

The Council has approved a University-wide Conflict of Interest Policy, which will take effect on 1 January 2022. The Policy is designed to present a risk-based and proportionate approach to managing conflicts of interests.

The Policy is available as a web document or can be downloaded as a pdf.

The following FAQs are provided to accompany the Policy:

About the new Policy

Many members of staff at the University are actively engaged in external activities, both within the UK and overseas. Because of these activities, most staff will encounter situations during their careers when personal interests could reasonably be perceived as affecting, or having the potential to affect, their ability to make impartial decisions on the University’s behalf. This does not imply improper conduct or lack of integrity. What is important is that all such conflicts are disclosed, reviewed and (if necessary) managed in order to avoid the risk of decisions being, or appearing to be, improperly influenced, and to prevent damage to the reputation of the individual or the University.

The aims of the Policy are to:

  • enable staff, plus student and external committee members, to recognise where their personal interests conflict with, or may reasonably be perceived to conflict with, their University duties;
  • communicate the expectations for declaring and recording of conflicts of interest; and
  • set out the processes for managing conflicts of interest in order to ensure that business decisions are made objectively and in the best interests of the University.

The Policy distinguishes between two types of disclosures, which will be recorded in two different types of register:

  • Heads of Institutions, plus members and regular attendees of the University’s principal, central, decision-making bodies, are required to declare any interests which constitute existing or potential conflicts with their University duties annually via an online declaration of interests form, which will be administered by the Governance and Compliance Division.  These declarations will be recorded in Committee or School-based registers of interests;
  • all other members of staff will only need to disclose conflicts of interest with their University duties when they first arise or become known, including when it is recognised that a conflict might reasonably be perceived. These conflicts will be recorded in local (institutional) registers of conflicts of interests.

‘Declarations of interest’ should also be a standing item at the beginning of every committee meeting, so that members can declare any conflicts of interest in relation to that specific agenda. Both the declarations and any mitigating actions should be minuted.

This approach recognises that for the large majority of members of staff at the University it will be sufficient to declare conflicts of interests with their University duties when they arise. The approach will also reduce the administrative burden on institutions.

Implementation plan

The Policy was developed in consultation with colleagues from across the University and has been approved by the Research Policy Committee, the Committee on Benefactions and External and Legal Affairs, the General Board and the Council. The Policy was announced via the Reporter on 21 July 2021 and members of the University were invited to provide feedback on the FAQs accompanying the Policy.  Over the summer the Governance and Compliance Division also piloted the annual declaration of interests form with the Audit Committee and a group of senior officers (including Heads of UAS Divisions).

The Policy, FAQs and annual declaration of interests form were revised in early Michaelmas Term to take account of feedback received from members of the University. The main change was to clarify that those who regularly attend meetings of the University’s principal, decision-making bodies, such as the Council or the Research Policy Committee, should participate in the annual declaration of interests process.  The original version of the Policy just asked members of those bodies to declare their interests.  For the purposes of the Policy, ‘regular attendees’ are those individuals who have a standing invitation to attend the meetings and who receive a full set of the unreserved papers. 

Implementation plan for Heads of Institutions and Departmental Administrators

Faculties, Departments and other institutions are asked to implement the Policy by:

  • bringing it to the attention of their staff, plus student and external members of their institution’s committees;
  • advising how individuals should declare any conflicts of interests with their University duties (for example, by email to the Head of the Institution or via a webform);
  • ensuring that an up-to-date register of conflicts of interests is maintained for their institution; 
  • determining, in liaison with the declarer, how to manage each conflict within their local context;
  • confirming the agreed actions to the declarer by email by 31 December; and
  • checking that ‘Declarations of Interest’ is a standing item on the agenda of every committee, and that any declarations and mitigating actions are minuted.

Please see the FAQ for Heads of Institutions and Departmental Administrators for further information and a flowchart of the process. 

By 1 January 2022, when the Policy takes effect, each institution's register of conflicts of interest should be up-to-date. If members of the institution do not have any conflicts with their University duties the register will have no entries.  The register should be updated throughout the year as new conflicts are declared.

Implementation plan for Heads and Secretaries of the Schools

Role in the annual declaration of interests process

Heads of School are asked to ensure that an up-to-date register of interests is maintained for the Heads of Institution within their School by:

  • reviewing any declarations of interest made by the Heads of Institution within their School via the online declaration of interests form;
  • determining, in liaison with the declarer, whether any actions are needed to manage these interests in their local context; and
  • recording the agreed actions in the register and sending confirmation to the declarer by email by 31 December.

By 1 January 2022, when the Policy takes effect, the School's register of interests should be up-to-date. The register should be updated throughout the year as new interests are declared.

Role in local conflicts of interest processes

The Schools, like all other institutions within the University, are asked to:

  • bring the Policy to the attention of their staff (i.e. staff within the School Office), plus members of their committees;
  • advise how individuals should declare conflicts of interests with their University duties (for example, by email to the Head of the School or via a webform);
  • ensure that an up-to-date register of conflicts of interests is maintained for their School;
  • determine, in liaison with the declarer, how to manage each conflict within their local context;
  • record the agreed actions in the register and send confirmation to the declarer by email by 31 December; and
  • check that ‘Declarations of Interest’ is a standing item on the agenda of every committee, and that any declarations and mitigating actions are minuted.

By 1 January 2022, when the Policy takes effect, the School's register of conflicts of interest should be up-to-date. If members of the School do not have any conflicts with their University duties the register will have no entries. The register should be updated throughout the year as new conflicts are declared.

Please see the FAQ for Heads and Secretaries of the Schools for further information and a flowchart of the process. 

In addition, if a Head of Institution within the School has an interest in a conflict being disclosed by a member of their institution the matter will be referred to the Head of the School for their decision about the appropriate way to manage the conflict.

Implementation plan for Chairs and Secretaries of the University's principal, central decision-making bodies

Chairs of all committees within the University should ask for declarations of interest in relation to the agenda at the start of each meeting. Secretaries are asked to add ‘Declarations of Interest’ as a standing item on the agenda if this is not already in place and to minute both the declarations and any mitigating actions.

During Michaelmas Term, the Governance and Compliance Division will ask members and regular attendees of the University's principal, central decision-making bodies to complete the annual declaration of interests form. A report containing the relevant declarations will be sent to the Chair in mid-November. Chairs (or their nominated delegate) are asked to ensure that an up-to-date register of interests is maintained for their committee/body, by:

  • reviewing any declarations of interest made by their members/regular attendees via the online annual declaration of interests form; and
  • determining, in liaison with the declarer, whether any actions are needed to manage these interests in the context of their body’s remit;
  • recording the agreed actions in the register and confirming the actions to the declarer by email by 31 December..

By 1 January 2022, when the Policy takes effect, the registers of interests should be up-to-date. The register should be updated throughout the year as new interests are declared.

Please see the FAQ for Heads of Institutions and Departmental Administrators for further information and a flowchart of the process. 

Contact for queries and feedback

We welcome feedback that will help us to improve the Policy, FAQs and declarations of interests process. Please send any queries or comments to the Governance and Compliance Division at GCDEnquiries@admin.cam.ac.uk.