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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, for implementation by 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 draft FAQs are provided to accompany the Policy (access will be via Raven login until the final versions are published in early Michaelmas Term)

 

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:

  • members of the University’s principal, central, decision-making bodies and Heads of Institutions are required to declare any interests which constitute existing or potential conflicts with their University duties annually via an online declaration of interests, which will be administered by the Governance and Compliance Division;
  • all other members of staff will only need to disclose conflicts of interest with their University duties when they arise. These conflicts will be recorded (and managed) locally in Faculties, Departments and other institutions.

In addition, ‘declarations of interest’ should 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 and request for feedback on the supporting materials

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 Council is conscious that, for the Policy to be successful, all members of staff need to be aware of their duties in relation to the Policy. The Council has agreed that the launch and implementation of the Policy will proceed in three steps.

In the first step, members of the University are invited to provide feedback on the FAQs accompanying the Policy, in particular with regard to whether those FAQs address all questions that they might have and where further clarifications are needed. Comments should be sent to GCDEnquiries@admin.cam.ac.uk by 6 September 2021.

During the first step, the Governance and Compliance Division will also pilot the annual declaration of interests form with the Audit Committee and a group of senior officers (including Heads of UAS Divisions) over the summer. Comments from members of the University, as well as the findings of the trial of the annual declaration of interests form, will be taken into account in drafting the final version of the FAQs.

The Policy will be launched, as the second step, in early Michaelmas Term 2021. During that term, Faculties, Departments and other institutions will need to prepare for the implementation of the Policy and further guidance will be provided by early October to assist with this.

Implementation, the last step, will start from 1 January 2022.