Conflict of Interest Principles and Examples

Staff, students and others working in the University are encouraged to discuss issues related to conflicts of interest with Heads of Department, colleagues, mentors, supervisors, tutors, or others as appropriate.

Additional information

Research

Category	Principles	Guidance
Spinout Formation	All academics involved in the formation of a new spinout should complete a conflict of interest management plan, which is to be reviewed by Research Services and approved by the Head of Department before the initial investment can go through, or before the company starts operations.	Guidance on spinout companies
Intellectual property	If a researcher has a financial interest in the licensee (or proposed licensee) of University intellectual property they should disclose this, and step back from the negotiations, which should be managed by Oxford University Innovation. The IP Rights Management team manages any negotiations with third party collaborators or research funders in respect of rights for commercialisation.	Intellectual property
Applying for grants and negotiating contracts	Staff and students should declare all conflicts when applying for grants, negotiating contracts etc. In particular, financial conflicts need to be declared to avoid doubts being cast over the validity of research, and subsequent potential reputational damage.	Research integrity
Publishing	Authors submitting a manuscript should disclose any 'significant financial interest' or other relationship with the manufacturers of any commercial products or providers of commercial services discussed in the manuscript and any financial supporters of the research. The intent of such disclosures is not to prevent an author with a significant financial or other relationship from publishing a paper, but rather to provide readers with information upon which to make their own judgements.	Publication and authorship

Roles and Activities Outside the University

Category	Principles
External Appointments (starting a new business, consultancy or advisory work, directorships etc)	As set out in the regulations on the holding of outside appointments, Head of Department approval should be requested in advance for: Holding an outside appointment, Holding an underlying appointment with a previous employer, at times when you would be expected to be working for the University, Setting up or taking a financial interest in any business or other external entity not publicly listed on a stock exchange and which could be conceived as creating a conflict of interest, Undertaking consulting, Becoming a director of an external entity* (including university subsidiaries or joint ventures) Holding a stake in any external entity which could give rise to a perceived or actual conflict of interest with your University role. Where actual or potential conflicts of interest are identified, a COI management plan should be agreed. *Directors should particularly note their duties under Company Law.

Category

Principles

External Appointments (starting a new business, consultancy or advisory work, directorships etc)

As set out in the regulations on the holding of outside appointments, Head of Department approval should be requested in advance for:

Holding an outside appointment,
Holding an underlying appointment with a previous employer, at times when you would be expected to be working for the University,
Setting up or taking a financial interest in any business or other external entity not publicly listed on a stock exchange and which could be conceived as creating a conflict of interest,
Undertaking consulting,
Becoming a director of an external entity* (including university subsidiaries or joint ventures)
Holding a stake in any external entity which could give rise to a perceived or actual conflict of interest with your University role.

Where actual or potential conflicts of interest are identified, a COI management plan should be agreed.

*Directors should particularly note their duties under Company Law.

Guidance
Outside appointments guidance for academic staff and academic-related staff Consultancy policy and procedures Managing Responsibilities and Interest for University Employees Forming Companies Guidance for Subsidiary Directors

Guidance

Outside appointments guidance for academic staff and academic-related staff

Consultancy policy and procedures

Managing Responsibilities and Interest for University Employees Forming Companies

Guidance for Subsidiary Directors

Category	Principles
External Appointments (use of University resources)	Members of staff should not make use of University resources when undertaking consultancy work or work for external organisations, unless express permission has been granted by the department. Staff members' primary commitment should be to the University, and appointments should be managed so that they do not compete with duties to the University (time, teaching schedule, use of resources etc).

Category

Principles

External Appointments (use of University resources)

Members of staff should not make use of University resources when undertaking consultancy work or work for external organisations, unless express permission has been granted by the department.

Staff members' primary commitment should be to the University, and appointments should be managed so that they do not compete with duties to the University (time, teaching schedule, use of resources etc).

Guidance
Outside appointments guidance for academic staff and academic-related staff Consultancy policy and procedures Guidance for HoDs is available on considerations when reviewing outside appointment requests

Guidance

Outside appointments guidance for academic staff and academic-related staff

Consultancy policy and procedures

Guidance for HoDs is available on considerations when reviewing outside appointment requests

Student Supervision and Teaching

Category	Principles	Guidance
Admission, supervision, academic progress	Staff with a close personal or familial relationship with a student or a student's family should not be involved in decisions about that student's admission, supervision or academic progress, or the award of any studentships, prizes or other grants to the student. If a member of a panel making decisions about awarding studentships is the supervisor of an applicant, both the supervisor and the student should declare an interest.	Is provided in training for graduate admissions staff. Guidance on Staff and Student Relationships

Category

Principles

Guidance

Admission, supervision, academic progress

Staff with a close personal or familial relationship with a student or a student's family should not be involved in decisions about that student's admission, supervision or academic progress, or the award of any studentships, prizes or other grants to the student.

If a member of a panel making decisions about awarding studentships is the supervisor of an applicant, both the supervisor and the student should declare an interest.

Is provided in training for graduate admissions staff.

Guidance on Staff and Student Relationships

Other University Activities (Committee Work, Procurement, Recruitment, Admissions, Contract Negotiation)

Category	Principles	Guidance
Admissions Recruitment Contract negotiation	No member of the University should offer paid services to student applicants. Staff involved in admissions, recruitment or contract negotiation should neither deal with, nor make decisions about, applicants or other parties in negotiations that are known to them. Where it is not practical to be entirely removed from a process, advice should be taken on how to ensure the conflict is declared and managed transparently. For example, a member of staff would not be the sole decision-maker in the appointment, hiring, promotion, supervision or evaluation of a person with whom they have a close personal relationship. An academic or a non-academic member of staff who is on the board of governors of a school would not be involved in considering a student from that school for an undergraduate place.	Guidance on the Recruitment Process Guidance on Working with Relatives and Partners
Procurement	If a member of staff has a conflict of interest (arising from a personal relationship or an outside appointment) relating to the procurement of goods and services, they cannot be involved in the purchasing decision.	COI Policy Appendix 5.1-5.3 Financial Regulations - Purchasing and Conflicts of Interest Purchasing - Managing Difficult Situations
Committee work	Committee members should declare any conflicts either at the start of the meeting, or at the start of the item in question. It is then the responsibility of the chair to decide how to proceed. The declaration should be noted in the committee minutes. Committee membership may give rise to conflicts of interest with other roles, and committee members should recognise this and not take part in a decision in which they have a conflict of interest. For example, no individual should be involved in University scrutiny and decision-making regarding proposals they have developed as a director of a subsidiary company or Joint Venture.	<Template paper for committee> Guidance for Subsidiary Directors
Appointments as directors of subsidiaries or joint ventures	Head of Department approval should be granted as for outside work and the holding of outside appointments, as set out in the regulations and the associated policy, declaring any conflicts and agreeing appropriate management strategies. Directors should particularly note their duties under Company Law. Guidance is available to help individuals recognise where their responsibilities to the University as employees, trustees or other decision-makers differ from and may come into conflict with their responsibilities and duties as a company director.	Outside appointment guidance for academic staff and academic-related staff Guidance for Subsidiary Directors

Category

Principles

Guidance

Admissions

Recruitment

Contract negotiation

No member of the University should offer paid services to student applicants.

Staff involved in admissions, recruitment or contract negotiation should neither deal with, nor make decisions about, applicants or other parties in negotiations that are known to them. Where it is not practical to be entirely removed from a process, advice should be taken on how to ensure the conflict is declared and managed transparently.

For example, a member of staff would not be the sole decision-maker in the appointment, hiring, promotion, supervision or evaluation of a person with whom they have a close personal relationship.

An academic or a non-academic member of staff who is on the board of governors of a school would not be involved in considering a student from that school for an undergraduate place.

Guidance on the Recruitment Process

Guidance on Working with Relatives and Partners

Procurement

If a member of staff has a conflict of interest (arising from a personal relationship or an outside appointment) relating to the procurement of goods and services, they cannot be involved in the purchasing decision.

COI Policy Appendix 5.1-5.3

Financial Regulations - Purchasing and Conflicts of Interest

Purchasing - Managing Difficult Situations

Committee work

Committee members should declare any conflicts either at the start of the meeting, or at the start of the item in question. It is then the responsibility of the chair to decide how to proceed. The declaration should be noted in the committee minutes.

Committee membership may give rise to conflicts of interest with other roles, and committee members should recognise this and not take part in a decision in which they have a conflict of interest.

For example, no individual should be involved in University scrutiny and decision-making regarding proposals they have developed as a director of a subsidiary company or Joint Venture.

Guidance for Subsidiary Directors

Appointments as directors of subsidiaries or joint ventures

Head of Department approval should be granted as for outside work and the holding of outside appointments, as set out in the regulations and the associated policy, declaring any conflicts and agreeing appropriate management strategies. Directors should particularly note their duties under Company Law.

Guidance is available to help individuals recognise where their responsibilities to the University as employees, trustees or other decision-makers differ from and may come into conflict with their responsibilities and duties as a company director.

Outside appointment guidance for academic staff and academic-related staff

Guidance for Subsidiary Directors

Examples for Academics

Situation	Procedure or Policy Requirements
An academic holds a position (for example as a consultant, director or advisor) in an enterprise that may also have an interest in influencing government or other policy.	Approval for the outside appointment should be obtained before it is taken up. Before approval, any potential conflicts should be identified and a management plan agreed.

Where is the conflict or potential for conflict?	How can it be managed?
Are there any conflicts between the policy influence aims of this organisation and the wider University or research collaborators? Are the individual and their HoD comfortable with the role the organisation plays in relation to policy engagement and influence? Is there a risk their name or research will be linked to, or used to add weight to, a policy position that they don't agree with?	Declarations of interests made regularly and openly so there is transparency within the University and with research collaborators about links with the enterprise and vice versa. There should be clarity of roles and clear expectations and scope for any work that the individual does for the enterprise.

Where is the conflict or potential for conflict?

How can it be managed?

Are there any conflicts between the policy influence aims of this organisation and the wider University or research collaborators?

Are the individual and their HoD comfortable with the role the organisation plays in relation to policy engagement and influence?

Is there a risk their name or research will be linked to, or used to add weight to, a policy position that they don't agree with?

Declarations of interests made regularly and openly so there is transparency within the University and with research collaborators about links with the enterprise and vice versa.

There should be clarity of roles and clear expectations and scope for any work that the individual does for the enterprise.

Situation	Procedure or Policy Requirements
An academic who has a senior editorial position with a commercial journal is also on a University library committee that recommends journal subscriptions.	Governance of the University must be conducted with close regard to the risks of financial and non-financial conflicts of interest.

Where is the conflict or potential for conflict?	How can it be managed?
It is in the interest of the journal that the University subscribes but the decision on whether that is right for the University should be made independently of influence by journal editors. Committee members should not take part in a decision in which they have a conflict of interest.	The conflict should be declared at the start of any meeting where journal subscriptions are to be discussed, and/or at the start of the item in question. It is then the responsibility of the chair to decide how to proceed. The declaration and action taken should be noted in the committee minutes. Possible actions might include the individual taking no part in the discussion, or leaving the meeting for the item.

Where is the conflict or potential for conflict?

How can it be managed?

It is in the interest of the journal that the University subscribes but the decision on whether that is right for the University should be made independently of influence by journal editors.

Committee members should not take part in a decision in which they have a conflict of interest.

The conflict should be declared at the start of any meeting where journal subscriptions are to be discussed, and/or at the start of the item in question.

It is then the responsibility of the chair to decide how to proceed. The declaration and action taken should be noted in the committee minutes.

Possible actions might include the individual taking no part in the discussion, or leaving the meeting for the item.

Examples for Researchers

Situation	Procedure or Policy Requirements
A researcher has a financial interest in the licensee (or proposed licensee) of University intellectual property.	This is one of the non-employment situations that must be disclosed and approved under the outside appointment approval process. Before approval, any potential conflicts should be identified and a management plan agreed.

Where is the conflict or potential conflict?	How can it be managed?
The license terms which are most beneficial for the researcher as an individual may not be the most appropriate for the University.	The individual should step back from license negotiations which should be managed by Oxford University Innovation. The IP Rights Management team manages any negotiations with third party collaborators or research funders in respect of rights for commercialisation.

Situation	Procedure or Policy Requirements
A researcher holds a position (for example as a director) in an enterprise that may wish to restrict or otherwise manage adverse research findings for commercial reasons.	Approval for the outside appointment should be obtained before it is taken up. Before approval, any potential conflicts should be identified and a management plan agreed.

Where is the conflict or potential for conflict?	How can it be managed?
In addition to raising questions of academic integrity, non-publication of research findings can have an impact on others in the group and on the careers of more junior staff and research students.	The researcher should step back from decision-making in the University relating to research sponsored by the enterprise. See also: Managing Responsibilities and Interest of University Employees Forming Companies

Where is the conflict or potential for conflict?

How can it be managed?

In addition to raising questions of academic integrity, non-publication of research findings can have an impact on others in the group and on the careers of more junior staff and research students.

The researcher should step back from decision-making in the University relating to research sponsored by the enterprise.

Examples for Members of Staff and Committee Attendees

Situation	Procedure or Policy Requirements
A member of staff chairs a University committee which is to consider the allocation of funds to be shared between a number of colleges, including their own.	Governance of the University must be conducted with close regard to the risks of financial and non-financial conflicts of interest.

Where is the conflict or potential for conflict?	How can it be managed?
Committee members should not take part in a decision in which they have a conflict of interest. Conflicts of interest are about the situation rather than the outcome. Even if the individual feels able to exercise independent judgement, there is likely to be a perception that they would be biased in favour of their own college.	As the chair, the individual should identify that there is a conflict, ideally before the meeting where funding allocations are to be discussed. Another member could chair for that agenda item and the chair could step back from the discussion and decision. The declaration and action taken should be noted in the committee minutes.

Where is the conflict or potential for conflict?

How can it be managed?

Committee members should not take part in a decision in which they have a conflict of interest.

Conflicts of interest are about the situation rather than the outcome. Even if the individual feels able to exercise independent judgement, there is likely to be a perception that they would be biased in favour of their own college.

As the chair, the individual should identify that there is a conflict, ideally before the meeting where funding allocations are to be discussed. Another member could chair for that agenda item and the chair could step back from the discussion and decision.

The declaration and action taken should be noted in the committee minutes.

Situation	Procedure or Policy Requirements
A regular attendee at a committee making resource allocation decisions (e.g. PRAC, BESC, IT) is also a director of one of the subsidiary companies responsible for delivering on certain projects on behalf of the University.	Governance of the University must be conducted with close regard to the risks of financial and non-financial conflicts of interest.

Where is the conflict or potential for conflict?	How can it be managed?
Attendees do not vote on decisions but may prepare papers, make other contributions to meetings or otherwise influence those decisions by the information they share or withhold. Through their attendance at a committee, an attendee may become aware of information which affects the company which they would not otherwise have access to.	Declarations of interests should be made regularly and openly so there is transparency within the University and within committees about the interests of both members and attending officers. The conflict should be declared at the start of any meeting where relevant resource allocations are to be discussed, and/or at the start of the item in question. It is then the responsibility of the chair to decide how to proceed. The declaration and action taken should be noted in the committee minutes. A possible action would be for the individual to leave the meeting for the discussion once they have presented any relevant information and responded to questions.

Where is the conflict or potential for conflict?

How can it be managed?

Attendees do not vote on decisions but may prepare papers, make other contributions to meetings or otherwise influence those decisions by the information they share or withhold.

Through their attendance at a committee, an attendee may become aware of information which affects the company which they would not otherwise have access to.

Declarations of interests should be made regularly and openly so there is transparency within the University and within committees about the interests of both members and attending officers.

The conflict should be declared at the start of any meeting where relevant resource allocations are to be discussed, and/or at the start of the item in question.

It is then the responsibility of the chair to decide how to proceed. The declaration and action taken should be noted in the committee minutes.

A possible action would be for the individual to leave the meeting for the discussion once they have presented any relevant information and responded to questions.

Conflict of Interest Principles and Examples

Information for departments and individuals

Additional information