Policy on Conflict of Interest
Bangor University considers that the establishment of links between members of staff and outside bodies, such as government departments, commercial companies and industry, is not only in the public interest but also benefits the University and the individuals concerned. It is possible however that such links may give rise to a potential conflict of interest. The University is committed to the principle that the activities of members of staff should not give rise to situations where they have, or appear to have, a conflict of interest.
This document sets out the University’s policy in relation to possible conflicts of interest and provides guidelines for members of staff in assessing whether, in relation to proposed activities, a potential conflict of interest exists. It also outlines the procedures for disclosing any perceived, potential or actual conflicts. Accordingly, rather than seek to prohibit all activities that might give rise to a conflict of interest, this Policy provides for a three-fold approach:
- Disclose always;
- Manage the conflict where practicable;
- Prohibit the activity when necessary to protect an individual or the public interest or the interests of Bangor University.
It is the duty of all members of staff to disclose any actual, perceived or potential conflict of interest as defined by this Policy. Failure to disclose a conflict of interest may result in disciplinary action.
For the purpose of this Policy, the following definitions apply:
2.1 “Conflict of interest” is defined as:
An action or situation, actual, potential or perceived, that could lead an individual to be influenced by considerations of personal gain, or gain to immediate family, whether financial or otherwise. A conflict may be direct or indirect. Such situations may include but are not limited to:-
- Executive and Non-Executive Directorships
- Licensing of Intellectual Property
- Outside Activities and Consultancy
- Research projects
- Equity Interests
- Teaching and Assessment of close relatives (The University’s Policy on Staff and Student Relationships gives further guidance on this matter)
- Continuous Professional Development delivery of courses/programmes
The term includes conflict of duty (where, for example, an individual’s duty to the University conflicts with that person’s duties as a director of a spin-out company) , rights, obligations, interests and similar conflict whether as an individual or as a representative of Bangor University.
2.2 “Member of staff” is defined as all academic (including honorary staff), academic related, fixed-term contract staff and all other members of staff including technical, clerical / secretarial and manual staff.
2.3 “Confidential information” includes any information, such as medical records, human resource records, student records, security records, business information, intellectual property, database rights, information about contractor/subcontractor selection ahead of official announcements, research information (including, but not limited to, research results, tables, graphs, formulae, apparatus, experimental set-up, computer code, engineering drawings, parts list) and laboratory notebooks, that needs to be kept restricted.
All members of University staff as well as members of Council are required to declare any external interests.
Such declarations are entered on a Register which is maintained by the Planning and Governance Office and includes the name of each individual, as well as the information supplied on the declaration form. Staff are requested to complete a form electronically on an annual basis. If a form is not returned by a member of staff the University will assume that the individual has no interests to declare.
The Register is a public document, inspected regularly by the auditors and the HEFCW Audit and Risk Assurance Service. The requirements of the Data Protection Act 1998 must be adhered to in relation to all personal information.In all cases, members of Council and staff are advised to include any personal, financial or beneficiary interests which might - or could, if publicly known - be perceived as interfering with their responsibilities as members of Council or staff to act solely in the best interests of the University. They are advised to consider registering relevant known interests of spouses, partners or children. Members are also advised to disclose any properties (whether freehold or leasehold) that are adjacent to any property owned by or in use by the University. They are advised, however, to inform the Head of Compliance as soon as possible of any substantive changes to their circumstances which require to be entered on the Register and are also required to provide updated information on request. In addition to declarations made from time to time under the terms of this Policy, records are updated regularly and members are required to provide updated information on request.
An annual audit of the Register is undertaken which is facilitated by the member of staff within the Planning and Governance Office who has responsibility for this Policy. The University also reserves the right to monitor and undertake random auditing of compliance with this Policy.
In addition, any member of staff who is aware of a potential conflict of interest, as defined in section 2.1 of this Policy, must, in the first instance, raise the matter (where they are members of staff of an academic department) with their Head of School, who should also inform the Head of College, or (where they are members of staff in a central service department) with their Head of Department, who should also inform the Head of Compliance.