University-wide Conflict of Interest Policy

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Summary with links to the Policy and associated FAQs

The University-wide Conflict of Interest Policy is designed to present a risk-based and proportionate approach to managing conflicts of interests. It is available as a web document. 

The following FAQs are provided to accompany the Policy:

About the Policy

Many members of staff at the University are actively engaged in external activities, both within the UK and overseas. Because of these activities, most staff will 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 Policy are to:

  • 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);
  • communicate the expectations for declaring and recording of conflicts of interest (see Section D); and
  • 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). 

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

Implementing the Policy

Actions for Heads of Institutions and Departmental Administrators

Heads of Institutions are asked to implement the Policy by:

  • bringing it to the attention of all their staff, plus student and external members of their institution’s committees;
  • advising 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) and reminding them on an annual basis to declare any new conflicts or significant changes to previously declared conflicts; 
  • ensuring that an up-to-date register of conflicts of interests and associated mitigating actions is maintained for their institution; 
  • determining, in liaison with the declarer, how to manage each conflict within their local context;
  • recording the agreed actions in the register and confirming the outcome in writing to the declarer;
  • undertaking an annual review of actions for previously declared conflicts to ensure they remain relevant; and
  • checking 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.

Please see the FAQ for Heads of Institutions and Departmental Administrators for further information, including a flowchart of the process and a template email for the annual reminder to staff. 

Actions for Heads and Secretaries of the Schools

The Schools help to implement several aspects of the Policy as follows:

Role in the annual declaration of interests process

Heads of School (or their nominated delegate) are asked to ensure that an up-to-date register of interests is maintained for the Heads of Institutions within their School by:

  • reviewing any declarations of interest made by the Heads of Institutions within their School via the online declaration of interests form;
  • determining, in liaison with the declarer, whether any actions are needed to manage these interests in their local context;
  • recording the mitigating actions in the School's register of interests within the online system; and
  • updating the register throughout the year as new interests are declared.

Role in local conflict of interest processes

The Schools, like all other institutions within the University, are asked to:

  • bring the Policy to the attention of their staff (i.e. staff within the School Office), plus members of their committees;

  • advise how individuals should declare conflicts of interests with their University duties (for example, by email to the Head of the School or via a webform) and remind them on an annual basis to declare any new conflicts or significant changes to previously declared conflicts;

  • ensure that an up-to-date register of conflicts of interests is maintained for their School;

  • determine, in liaison with the declarer, how to manage each conflict within their local context;

  • record the agreed actions in the register and send confirmation in writing to the declarer;

  • undertake an annual review of actions for previously declared conflicts to ensure they remain relevant; and

  • check that ‘Declarations of Interest’ is a standing item on the agenda of every committee within the School, and that any declarations and mitigating actions are minuted.

See the FAQ for Heads and Secretaries of the Schools for further information, including a flowchart of the process and a template email for the annual reminder. 

NB. If a Head of Institution within the School has an interest in a conflict being disclosed by a member of their institution the matter will be referred to the Head of the School for their decision about the appropriate way to manage the conflict.

Actions for Chairs and Secretaries of the University's principal, central decision-making bodies

‘Declarations of Interest’ should be a standing item on the agenda of every meeting and both the declarations and any mitigating actions should be recorded in the minutes.

During Michaelmas Term, the Governance and Compliance Division asks members and regular attendees of the University's principal, central decision-making bodies to complete the online annual declaration of interests form. Chairs (or their nominated delegate) are asked to ensure that an up-to-date register of interests is maintained for their committee (or equivalent), by:

  • reviewing any declarations of interest made by their members/regular attendees 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 committee’s remit;
  • recording the agreed actions in the register (including noting where no actions are needed);
  • undertaking an annual review of actions for previously declared conflicts to ensure they remain relevant; and
  • updating the register throughout the year as new interests are declared.

Please see the FAQ for principal, central decision-making bodies for further information and a flowchart of the process. 

Contact for queries and feedback

We welcome feedback that will help us to improve the Policy, FAQs and declarations of interests process. Please send any queries or comments to the Governance and Compliance Division via CoI@admin.cam.ac.uk.