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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

**Buildings 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 and Diversity 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

Joint Committee on Development

Museums Committee

Planning and Resources Committee

**Postdoctoral Matters Committee

Press and Assessment Board

Property Board

Remuneration Committee

Research Policy Committee

Resource Management Committee

University Council

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. 

**These committees are included in the DoI process for the first time in 2022-23.

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

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.

Q. What is expected of Chairs?

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 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 in writing; and
  • undertaking an annual review of actions for previously declared conflicts to ensure they remain relevant.

The register should be updated throughout the year as new interests are declared.  See the flow chart below for an outline of the process. Please note that as development of the reviewer side of the DoI system took longer than planned we have extended the deadline for mitigating actions to be added to the system until early in 2023(rather than 1 January as indicated in the flow chart).

Q. Who should review the declarations?

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).

If the Chair has an interest in a declaration they should contact CoI@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 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?

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

Process and guidance for reviewers

The reviewer system is implemented within Microsoft Teams. This has two key parts:

  1. the approvals app, where all the interests are listed for review and into which you can add the appropriate mitigating actions.
  2. a MS Team that contains your register(s) and UIS’s guidance on using the system. NB. you will receive a notification that UIS have added you to this team (UoC_Declarations of Interests Reviewers)

This system is intended to be more secure and auditable. After the initial set-up it should also be easier to maintain as you’ll be notified of any updates outside the normal cycle, all the information will be stored centrally and you won’t need to transfer actions from one version of the spreadsheet to another.

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. checking that the mitigating actions for interests that were declared last year remain appropriate (and – as a one-off action - transferring them from last year’s spreadsheet to the new system); and
  2. agreeing and entering any mitigating actions for newly declared interests – these are flagged in the system for convenience.

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.

As the teams plug-in is a new way of working, UIS have drafted full guidance on how to use the system. This includes:

Tips from the pilots

We have piloted the new system with two committees and feedback was that it was quick and straightforward once the Secretary was set-up in the system. Three tips from the pilots are to:

  1. Filter the list of interests in the approvals app to look at each individual’s interests in turn (this is point 3 in the guidance on recording DoI mitigations). We found this much quicker than looking at the full list in the app, which has a tendency to jump around when you scroll through the list.
  2. View the register in a separate tab to the approvals app when you are reviewing the interests. You can then ‘drill down’ in the register to see further information about a particular interest which can provide useful context (this is point 3 in the guidance on viewing your register). The register is a live doc, so you will see the mitigating actions appear in the register after you’ve entered them in the app.
  3. It is possible to export the register (again 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.

Once you have entered a mitigating action it is not currently possible for you as reviewers to edit that action (e.g. to correct a typo or if you wish to amend the action). We realise that this is frustrating and have flagged it to UIS as our priority for the next iteration of the system. The workarounds this year are that either:

  • we can amend the mitigating action on your behalf if you send the amended text and mitigation reference to CoI@admin.cam.ac.uk; or
  • you can request (again via CoI@admin.cam.ac.uk) that we/UIS resend that interest to you so that you can add in the updated action. Notes on how to do this are included towards the end of the guidance on recording DoI mitigations.

Q. What about in-year membership changes?

In 2022-23, the annual update exercise will run in November/December, so that the registers are up-to-date very early in the 2023 calendar year.  From 2023 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).  These interests will be sent to you 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.