Actions required through the research lifecycle

Grant application/contract negotiation stage

The conflict of interest policy requires all researchers to indicate any actual or perceived conflict of interest, or any circumstances that could lead to any actual or perceived conflict of interest, at the research grant application or contract negotiation stage.

The confirmation questions in X5 include:

  • Will the acceptance of the grant or contract lead to potential or real conflict of interest (eg do you hold related consulting arrangements, financial interests, such as equity holding in the sponsor, fiduciary responsibility towards the sponsor, such as board membership)?
  • Has any actual, potential or perceived conflict of interest been brought to the attention of the HoD/ HoDiv/ Conflict of Interest Committee (as appropriate) and have agreed safeguards been put in place, where necessary in accordance with the University's policy?

The department will work with the principal investigator to prepare the X5 costing and will record the answers to these questions. Please note that through X5 workflow, the head of department (or their delegated authority) and Research Services will review the costing and the answers to these questions online. The head of department will be asked to consider the issues raised in the X5 costing, in accordance with the University policy on conflict of interest, and to advise Research Services in writing that the appropriate action has been taken prior to acceptance by the University of the proposed research grant or contract.

Subsequent research stages

Situations related to conflict of interest may develop at any time during the 'research lifecycle'. They may arise from or relate to the research activities of University staff, students, academic visitors and collaborators, including:

  • changing personal circumstances
  • research supervision
  • publications
  • consultancy
  • invitations to take part in external activity
  • external research funding
  • involvement in technology transfer initiatives (eg licensing or sale of IP or creation of spin-out companies)

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The University's conflict of interest policy places the onus on the individual involved to recognise and disclose activities that might give rise to conflicts of interest or the perception of conflicts and to ensure that such conflicts are seen to be properly managed or avoided.
 

The general rule, with the exception of committee business, is that disclosure should be made at the time the conflict first arises, or it is recognised that a conflict might be perceived, in writing to the head of department (or equivalent).
 

As described in the policy, many situations will require nothing more than a declaration and a brief written record of that declaration, which must be held in the department's or college's records.

Some instances will however need to be dealt with by agreeing how the conflict can be actively managed.

There are some instances where the general procedure is varied and further steps are required to obtain approval not only from the head of department (or equivalent) but also from a designated University official, as set out in the table at further procedural guidance of the policy.

For example, staff or students who have a financial interest in a company that may reasonably appear to be affected by the results of a proposed biomedical or clinical research must disclose that interest and submit a conflict of interest plan/approach to both the head of department and head of division.
 

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