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.

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 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.

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.

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.