5.1. A conflict of interest arises where the commitments and obligations owed by a member of staff or student to the University or to other bodies, for example a funding body, are likely to be compromised, or may appear to be compromised, by: a) personal gain, or gain to immediate family (or a person with whom the staff or student has a close personal relationship)1, whether financial or otherwise; or b) the commitments and obligations that person owes to another person or body.
5.2. There can be situations in which the appearance of conflict of interest is present even when no conflict actually exists. Thus it is important for all staff and students when evaluating a potential conflict of interest to consider how it might be perceived by others. Apparent or perceived conflicts of interest can be as damaging as actual conflicts of interest.
5.3. In order to recognise actual or perceived conflicts of interest, key interests need to be identified. Within the scope of this Policy, there are three main dimensions to be considered:
Dimension 1: roles and relationships
Actual or potential conflicts generally arise from:
- roles or activities involving parties outside the University;
- roles held by staff and students outside the University;
- multiple roles held by staff and students inside the University;
- committee membership and roles involving decision-making in or on behalf of the University, departments, faculties or other units; and
- close personal relationships.
Dimension 2: activities giving rise to potential conflicts
Actual or potential conflicts generally arise from:
- spinouts and other companies in which staff and students have an interest;
- intellectual property;
- complex commercial transactions and arrangements;
- conduct and funding of research;
- external activities and appointments;
- admissions; and
Dimension 3: financial and non-financial conflicts
Conflicts of interest may be financial, non-financial or both.
Financial conflicts of interest
5.4. A financial conflict of interest, for the purposes of this Policy, is one where there is or appears to be opportunity for personal financial gain, financial gain to close relatives or close friends, or where it might be reasonable for another party to take the view that financial benefits might affect that person’s actions. A conflict will arise if the financial interest might provide, or be reasonably seen by others to provide, an incentive to the individual which affects their actions and where they have the opportunity to affect a University decision or other activity (because for example they are the decision-maker or the principal investigator on a research project).
5.5. ‘Financial gain’ or ‘financial interest means anything that has monetary value, including but not limited to:
- benefits in kind;
- hospitality and/or gifts;
- forgiveness of debt;
- discounts, bonuses or other favourable contract terms;
- equity interests (eg stocks, stock options or other ownership interests); and/or
- intellectual property rights (eg patents, copyrights and royalties from such rights).
5.6. The level of financial interest is not the determining factor as to whether a conflict should be disclosed. What might be ‘not material’ or ‘not significant’ for one person might be very significant for another. Good practice in many situations will mean the declaration of ‘any’ financial interest, however small.
5.7. The identification and management of conflicts of interest has become even more important in light of the significantly-increased level of financial and reputational risk arising from complex, high-risk, commercial transactions and arrangements.
- For examples of conflicts involving financial interests, see the accompanying guidance below (which includes specific guidance on spinouts and procurement decisions).
Non-financial conflicts of interest
5.8. Non-financial interests can also come into conflict, or be perceived to come into conflict, with a member of staff or student’s duties, obligations or commitments to the University. Such non-financial interests may include any benefit or advantage, including, but not limited to, direct or indirect enhancement of an individual’s career or education, or gain to immediate family (or a person with whom the person has a close personal relationship).
5.9. Ensuring that these conflicts of interest do not result in decisions or actions that can be called into question is particularly important for business propriety, supporting the University’s charitable status, and conducting research that conforms to the expected ethical and academic standards.
5.10. In order to identify potential conflicts of interest, students and staff should consider who they are acting for, and whether there are any competing motivations or interests that could influence them, or be seen to influence them.
- For examples of conflicts involving non-financial interests, see the accompanying guidance below (which includes specific guidance for UG Admissions, Graduate Admissions and Personnel Services).
 For the purpose of this policy, ‘immediate family’ is defined as follows: spouse or civil partner, son, daughter. However, the ‘close personal relationship’ giving rise to an interest could extend to the following (this is not intended to be an exhaustive list): unmarried partner, parent, brother, sister, grandparent, grandchild, mother-in-law, father-in-law, sister-in-law, brother-in-law, son-in-law, daughter-in-law, the (unrelated) child of an unmarried partner, as well as half and step members of family.