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FAQ for principal, central decision-making bodies

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. Which committees are included in the online declaration of interests form?

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 would seem appropriate that they maintain a register of standing interests:

Advisory Committee on Membership and External Nominations 

Audit Committee

Business Committee

Committee on Benefactions and External and Legal Affairs

Committee on the Membership of Committees

Committee on Prevent and Freedom of Speech

Council

Council Committee for the Supervision of the Student Union

Environmental Sustainability Strategy Committee

Equality and Diversity Committee

Estates Strategy Committee

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

General Board

*General Board's Education Committee (including its sub-committees: Examination and Assessment Committee and Examination Access and Mitigation Committee)

Health and Safety Executive Committee

Honorary Degree Committee

Human Resources Committee 

Information Services Committee

International Strategy Committee

Investment Board

Joint Committee on Development

Museums Committee

Planning and Resources Committee

Press and Assessment Board

Property Board

Remuneration Committee

Research Policy Committee

Resource Management Committee

University Sports Committee

*NB. the registers of interests for the General Board’s Education Committee and the Finance Committee should cover their sub-committees.  The Chair of the main committee should liaise with the Chairs of the sub-committees to agree actions as appropriate. 

Q. Why aren’t all University bodies included in the form?

The above list does not cover every central University-level body. During the pilot year of the form only the principal, central decision-making bodies are included.  We will review feedback at the end of the year and may expand the scope of the form to include other University bodies from 2022.

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.

Q. What is expected of Chairs?

GCDEnquiries@admin.cam.ac.ukChairs 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 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 confirming the outcome to the declarer by email by 31 December.

By 1 January 2022, when the Policy takes effect, the register of interests should be up-to-date. The register should be updated throughout the year as new interests are declared.  See the flow chart below for an outline of the process.

Q. Known limitations of the current design and workarounds

There are a couple of known limitations with the current design of the form – namely that individuals cannot amend their entries and there is no back button.  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 Chairs (or their delegates) to access the declarations that are relevant to them and record any management plans alongside the declarations.  In the meantime, if individuals need to add another interest at any point during the academic year, or realise that they made an error in your original submission, they can create a new entry via an open link.

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 Chairs are the most appropriate people to review 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).

If the Chair has an interest in a declaration they should contact the Governance and Compliance Division (mailto:GCDEnquiries@admin.cam.ac.uk?subject=Conflict%20of%20Interest%20Policy) 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 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?

Q. How should I record the actions and communicate them to the individuals concerned?

The Governance and Compliance Division will send a report on the declarations of members/regular attendees of the committee to the Chair as an excel workbook; this will include a column for Chairs to record the management plan for each interest.  In accordance with Section E of the Policy the Chair (or nominated delegate) should decide on the course of action for each declared interest, confirm this to the declarer in writing and record it in the committee’s register of interests. 

A template register is provided in Appendix 2 of the Policy for information.

Q. What about in-year membership changes?

In 2021 the annual update exercise will run in Michaelmas Term, so that the registers are up to date for the start of the 2022 calendar year.  In future years 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.  If your committee membership changes throughout the year please ask your new members to complete the online form, so that any potential conflicts are recorded and managed as appropriate.

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 should enter it into the online form via the open link.  The resulting information will be sent to you for inclusion in your register of interests.