FAQ for principal, central decision-making bodies

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 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.

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.

The Policy distinguishes between two types of disclosures, which are 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 is administered by the Governance and Compliance Division and the declarations are recorded in Committee or School-based registers of interests;
• all other members of staff 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 are recorded in the institution's register of conflicts of interests.

‘Declarations of interest’ are 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 is sufficient to declare conflicts of interests with their University duties when they arise. The approach also reduces the administrative burden on institutions.

The Policy states that Heads of Institution, plus members and regular attendees of the University’s principal, central decision-making bodies, should declare their interests annually. For the purposes of this 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.  In most cases this is likely to include (but not necessarily be limited to) the secretary and those who attend in an advisory capacity or as an observer.

The online annual declarations of interest form has been set up to facilitate this.  The following bodies are included in the form, as it seems appropriate that they maintain a register of standing interests:

Advisory Committee on Membership and External Nominations 

Audit Committee

Business Committee

Change and Programme Management Board

Committee on Benefactions and External and Legal Affairs

Committee on the Membership of Committees

Committee on Prevent and Freedom of Speech

Council Committee for the Supervision of the Student Union

Environmental Sustainability Strategy Committee

Equality, Diversity & Inclusion Committee

*Estates Committee

**Finance Committee (including its sub-committees: Business Sub-Committee and Assessment Committee)

General Board

General Board's Education Committee 

Health and Safety Executive Committee

Honorary Degree Committee

Human Resources Committee 

Information Services Committee

International Strategy Committee

Joint Committee on Development

Museums Committee

Planning and Resources Committee

Property Board

Remuneration Committee

Research Policy Committee

Resource Management Committee

Technical Sub-Committee of the Estates Committee (formerly known as the Buildings Committee)

University Council

University Sports Committee

*This committee is included in the DoI process for the first time in 2023-24.

**NB. the register of interests for the Finance Committee covers its sub-committees.  The Chair of the main committee should liaise with the Chairs of the sub-committees to agree actions as appropriate. 

The above list does not cover every central University-level body. For some bodies (for example, appointment committees where the membership is extremely variable) it will be more efficient to simply record declarations of interest in the minutes at the start of each meeting and to agree any actions to manage these declarations then. 

Members of local committees (e.g. Councils of the Schools, Faculty Boards and/or Degree Committees) should declare any standing conflicts of interests to the Head of Institution.

Chairs of all committees within the University should ask for any declarations of interest in relation to the agenda at the start of each meeting, so that these (and any mitigating actions) can be recorded in the minutes.  

In addition, Chairs of the University’s principal, central decision-making bodies (or their nominated delegates) are responsible for ensuring that an up-to-date register of interests is maintained for their committee (or equivalent), by:

• reviewing any declarations of interest made by members or regular attendees of their meetings via the online annual declaration of interests form;
• 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 (including noting where no actions are necessary); and
• undertaking an annual review of actions for previously declared conflicts to ensure they remain relevant.

In many cases the Committee Secretary will maintain the register of interests in the declaration of interest system on behalf of the Chair.  The register should be updated throughout the year as new interests are declared.  See the flow chart below for an outline of the process. 

Generally Chairs are the most appropriate people to determine the conflicts in the context of their body’s remit.  On occasion, the Chair may delegate this responsibility to a suitably qualified named individual (e.g. the Deputy Chair or Secretary).  Generally the Secretary will enter the mitigations to the declaration of interest system on behalf of the Chair.

If the Chair has an interest in a declaration they should contact CoI@admin.cam.ac.uk for advice on how to proceed.

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 committee’s register as you judge that no further action is required.  Please note that the Chair 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?

In accordance with Section E of the Policy the Chair (or nominated delegate) should decide on the course of action for each declared interest and ensure that it is recorded in the committee’s register of interests (by entering the mitigations in the declaration of interest system).  Please also specify who is responsible for implementing the mitigating action in the register if it is not self-evident.

At the end of the annual update process the declarer will receive a record of the mitigating actions that have been agreed for each of their declared interests.

Process and guidance for reviewers

A Review and Manage app has been created for reviewers that allows each interest to be reviewed and a mitigation recorded.  This automatically populates the committee's register of interests which can also be accessed via the app.  This system is intended to be more secure and auditable. 

We have added Chairs and Secretaries as reviewers to the system and recommend that the Secretaries should generally be responsible for adding the agreed mitigating actions to the system. This will be a two stage process:

1. confirming that the mitigating actions for interests that were declared last year remain appropriate (or amending them as necessary); and
2. agreeing and entering mitigating actions for any newly declared interests .

Last year we know that many Secretaries went through the declarations on a call with their Chair. We suggest that this might be a straightforward way to agree the mitigating actions for the Secretaries to input into the new system. At the end of the process UIS will send declarers a copy of the mitigating actions for their declared interests.

It is possible to export the register of interests (UIS have provided guidance on how to do this). While we are trying to move away from emailing spreadsheets containing sensitive personal data we recognise that some Chairs may find it more convenient to review the interests and check that last year’s mitigating actions remain appropriate offline, rather than on a call, so sending them an export of the register may be helpful.

For further information please see the training notes for reviewers on using the new App.

In 2023 the annual update exercise will run in Michaelmas Term, so that the registers are up-to-date for the start of the 2024 calendar year.  From 2024 onwards we plan to run the annual update process over the summer, so that the registers are up-to-date for the start of Michaelmas Term. We hope that this will work better for everyone.

If your committee membership changes during the year please notify us via CoI@admin.cam.ac.uk, so that we can check whether any new members already have a record in the system or whether we need to ask UIS to add them to the system. If your new members have already completed the form in another capacity we can just amend their record so that they also appear in your register. If they are entirely new to the DoI system we will send them an invitation to complete the form (and ask UIS to set them up with a crsid if they do not already have one).  You will be notified of any declarations for review outside the main cycle.

Similarly, if a new potential conflict arises for any of your current members – or there are material changes to any of their existing interests - they can login to the DoI system with their crsid via Declaration of Interests Form - Power Apps to update their declarations.