Conflicts of Interest
What is a Conflict of Interest?
All those undertaking research must be able to recognise situations and activities that might give rise to a real or potential conflict of interest, or could be perceived by others as a real or potential conflict of interest. Any such conflict, which could affect, or be perceived to affect, an individual’s judgement in any aspect of undertaking their research, must be disclosed as soon as it is recognised and necessary steps taken to ensure it is recorded, and either avoided or appropriately managed.
A conflict of interest can inappropriately affect research and risk compromising the validity or integrity of the research, the reputation of the researcher, their research group(s), department, school, institute, research centre and the University. They must be identified, disclosed and addressed to avoid poor research practice or potential misconduct.
Researchers should consider the potential for real or perceived conflicts of interest to arise related to their research not only prior to the start of the research activity but also during the lifetime of the project. Any personal interest relating to a potential funder or sponsor of research (e.g. directorship, shareholding, consultancy, etc.) must be disclosed prior to the application for a research grant or negotiation of a research contract with that funder or sponsor. Some funding bodies and ethics committees may require direct notification of certain interests. Researchers must ensure that they are aware of any such conditions and adhere to the specified requirements.
Disclosure will normally be made to the Head of Department (or nominee), in accordance with the University’s Financial Regulations and the Personal Conflicts of Interest Policy and, where related to research, must also be notified to the Director of Research & Impact Services. Directors of Research, Heads of Research Groups and Principal or Chief Investigators should be informed as appropriate.
If the conflict of interest identified is considered to be of a type and severity to pose a risk of fatally compromising the validity or integrity of the research, the research will not proceed unless or until the conflict can be adequately addressed through declaration(s) and/or specific safeguards relating to the conduct and reporting of the research.
Activities
The following activities (the list is not exhaustive) undertaken by employees or third parties associated with the University could create an actual or perceived conflict of interest.
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Use of the University's research or administrative facilities to pursue personal, business, commercial, or consulting activities.
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Any attempt to restrict rights governing the timing and content of publications, except in circumstances properly approved by the University to protect privacy, commercially sensitive proprietary information, and patentable inventions.
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Involvement in externally funded activity which might infringe the right of a student engaged in the activity to complete the degree for which they are registered, and/or to publish freely their findings (except in the circumstances referred to in sub-paragraph (b) above).
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A financial interest held by an individual (or by their immediate relative(s) or household member(s)) in an external enterprise engaged in activities closely related to that individual's line of research in the University. Examples of such interests are paid consultancies, paid service on a board of directors or advisory board, or equity holdings in or royalty income from the enterprise. The existence of such an interest does not necessarily imply conflict, but is likely to give an appearance of conflict, and should be declared.
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A personal involvement in any company or commercial enterprise which is in a contractual relationship with the University, or which is in the process of negotiating a contract with the University, where the employee has been concerned or connected with placing or negotiating the contract in question or with the research or other activity which the contract might cover.
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Application by family members or friends for employment in the University or in a related company, where an individual is in a position to influence the appointing process.
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Receipt of gifts or hospitality by an individual (or by their immediate relative(s) or household member(s) from a company or organisation offering goods or services to the University.
Funding From External Sources
The University supports and encourages its staff to seek external funding for their research activities and accepts funding for research from a wide and diverse portfolio of legal sources, in accordance with University financial regulations and ethical scrutiny framework. All applications and proposals made, and contracts and awards accepted relating to external research funding, are done so on behalf of and in the name of the University, through Research & Impact Services, in accordance with the University’s Financial Procedure 14 - Grants & Contracts (FP14a available for download).
However, it is recognised that there may be circumstances where ethical issues can arise when considering whether or not to apply for or accept funding for research from particular sources. It is important that the interests of all staff and the interests and the reputation of the University as a whole are safeguarded when seeking and accepting external funding.
While it is outside the scope of this guidance to provide an exhaustive list of specific examples of what may or may not be acceptable sources of funding, circumstances where the following may occur would cause concern and further advice should be sought from the Director of Research & Impact Services, in the first instance:
- Where a third party is involved and the original source of the funding is unknown or cannot be identified;
- Where a funding organisation wishes to place inappropriate restrictions on publication and exploitation of research which may lead to substantial ethical difficulties;
- Where a funding organisation is attempting to exert pressure to suppress or alter the results of the research which do not further, or may damage, its interests, commercial or otherwise;
- Where a member of staff may have an interest in a funding organisation. In such cases, reference should be made to the University’s Financial Procedure 1 - Conflicts of Interest Policies and Procedures;
- Where accepting funds from one source may compromise the ability of the University to apply for or accept funds from another source;
- Where the practices of a potential sponsor or their motives in commissioning the research may conflict with the mission, aims and objectives of the University;
- Where the ethical and political implications of undertaking research or accepting research funding from a particular source could result in negative publicity and/or may seriously damage the reputation of the University;
- Where the conduct of research may harm or place at undue risk members of the public, participants or staff.
Advice and Guidance
Further advice and guidance on any ethical considerations relating to the application for or acceptance of external funding for research activities should be referred to the Director of Research & Impact Services in the first instance, who may also seek advice from the Pro Vice Chancellor (Research) and the University Research Governance and Ethics Committee.
For further guidance, contact: Dr Navdeep Bains, Director of Research & Impact Services.
Further information:
Financial Procedure 1 – Conflicts of Interest Policies and Procedures
Financial Procedure 9 – Gifts Received by the University
Personal Conflicts of Interest – Guidance for Staff and Students