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FAQ for Heads of Institutions and Departmental Administrators

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:

  • 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,  The form will be administered by the Governance and Compliance Division and the 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 the institution's register 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.

Q. What do institutions need to do and when?

Heads of Institutions are asked to:

  • ensure that staff within their institutions, plus any student or external members of their institution’s committees, are made aware of this Policy;
  • advise 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);
  • ensure that an up-to-date register of conflicts of interests is maintained for their institution;
  • determine, in liaison with the declarer, how to manage each conflict within their local context;
  • record the agreed actions in the register of conflicts of interests (including noting where no actions are necessary) and confirm the outcome to the declarer by email by 31 December; and
  • check that ‘Declarations of Interest’ is a standing item on the agendas of the institution's committees, and that any declarations and mitigating actions are minuted.

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.

See the flow chart below for an outline of the process.

Q. Who 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 institution’s register as you judge that no further action is required.  Please note that the Head of Institution 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?

Q. How should actions be recorded and communicated to the individuals concerned?

In accordance with Section E of the Policy, the Head of the Institution (or their delegate) should: decide on the course of action for each declared conflict, confirm this to the declarer in writing, and record it in the institution’s register of conflicts of interests (see the template in Appendix 2).