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FAQ for Heads and Secretaries of the Schools

Q. Why has the University introduced a Conflict of Interest Policy?

The mission of the University of Cambridge is to contribute to society through the pursuit of education, learning and research at the highest international levels of excellence.  Accordingly, many staff of the University are actively engaged in external activities, both within the UK and overseas.  These activities may for example include: providing expert advice and media commentary; serving on the boards of public and private sector organisations; partnerships with business, charitable foundations, and healthcare; collaborative research and development; consultancy work; spin-out companies; and outreach work.  Alternatively, someone with a close personal connection to a member of staff may have such associations. In addition, many staff - or those with a close personal connection to them - will also be affiliated to, and owe duties to, one or more of the Colleges within the collegiate University.

Because of these activities, most staff will almost certainly 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 University’s new Conflict of Interest Policy are to:

  1. 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 (see Section C);
  2. communicate the expectations for declaring and recording such conflicts (see Section D); and
  3. 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 (see Section E).   

Most organisations have policies on disclosing and managing conflicts of interest: this Policy is consistent with those of other UK universities.  It does not differentiate between conflicts that arise from domestic or oversees interests.

Q. Who does this Policy apply to?

Section B of the Policy states that the Policy applies to all those working within the University at all levels (whether paid or unpaid), as well as to student and external members of University committees or equivalent bodies.  All individuals who fit the above definition are encouraged to read the Policy and the relevant FAQs.

Q. What are the main features of the Policy?

The Policy distinguishes between two types of disclosures, which will be recorded in two different types of register, both of which are relevant to the Schools:

  • 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 School or Committee-based registers of interests;
  • 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 in local (institutional) registers of conflicts of interests.

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.

Q. What are we asking the Schools to do?

The Schools are asked to help implement several aspects of the Policy as follows (also see the flowchart below):

  1. Role in the annual declarations of interest process

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

  • reviewing any declarations of interest made by Heads of Institutions 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 (including noting where no actions are necessary) and sending confirmation to the declarer by email by 31 December.

The register of interests should be up-to-date by 1 January 2022 when the Conflict of Interest Policy takes effect.

Heads of Schools will also receive personal links to the form so that they can declare their interests.  Their declarations will be sent to the Vice-Chancellor for review.

  1. Role in local conflict 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 (including noting where no actions are necessary) 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 within the School, 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.

If a Head of Institution within your 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.

Q. How does the declaration of interests process work?

The Governance and Compliance Division will send Heads of Institutions individual links to the declaration of interests form.  A report on the declarations made by Heads of Institutions within your School will be sent to the Head of School in mid-November.

There are a couple of known limitations with the current design of the declaration of interests form – namely that individuals cannot amend their entries and there is no back button.  This version of the form is only intended as an interim solution to avoid the need for a manual process and so reduce the burden on individuals and on those who are responsible for maintaining the registers. 

We aim to introduce a more integrated system for 2022-23, which should allow individuals to amend their entries and enable Heads of Schools (or their delegates) to access declarations that are relevant to them and record any management plans alongside the declarations.  In the meantime, we have flagged these limitations on the form and, as a workaround, advise individuals to create a new entry via an open link if they need to add another interest or realise that they made an error in their original submission.

We welcome feedback that will help us to further improve the form; please send any such comments to the Governance and Compliance Division (GCDEnquiries@admin.cam.ac.uk).

Q. Who should review the declarations?

Generally Heads of School are the most appropriate people to review the conflicts in their local context.  On occasion, the Head of School may delegate this responsibility to a suitably qualified named individual (e.g. the Deputy Head or Secretary).

If the Head of School has an interest in a declaration they should contact the Governance and Compliance Division (GCDEnquiries@admin.cam.ac.uk) for advice on how to proceed.

Q. What should I consider when deciding how to manage each disclosure?

Section E of the Policy sets out some possible ways of managing conflicts of interest.  These range from a simple record of the declaration, through more active management plans to (in extreme cases) avoidance of the conflict.  In some cases it may be sufficient to simply note the disclosure in the School’s register as you judge that no further action is required.  Please note that the Head of School has discretion to implement other solutions that are compatible with the principles in Section E.

In deciding on the most appropriate management plan for each disclosure you may like to consider:

  • whether the activity is in the interests of the University?
  • is the activity potentially detrimental to the University, either financially or reputationally?
  • how potentially material is the conflict?
  • is there any gain, financial or otherwise, to the individual or to any of their close personal connections?
  • can the activity be kept separate from the individual’s University duties?
  • is the conflict straightforward to manage?