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The University operates under English public law which requires the University to take decisions fairly. There should be no ability to doubt the impartiality of a University decision because of a decision-maker’s non-University interests.
This concept is expressed more broadly as principle 3 (Objectivity) of the Nolan committee’s seven principles of public life.
The University operates as an exempt charity and is required under English charity law to use its assets and resources only for its own statutory purposes (higher/further education and research).
The University’s Conflict of Interest policy accepts that outside interests are part of the richness which staff and Governors bring to their role at the University. Conflict of interest is, therefore, an unavoidable and expected part of university life and must be managed routinely under the University’s processes.
This policy and its attendant rules are part of the University’s Financial Regulations which should be referred to in parallel.
The policy and its attendant rules bind all University employees, all members of the Board of Governors, students employed or sponsored by a third party, post-graduate research students and others working in the University such as visiting academics.
Where the text here refers to employees or staff, it covers also members of the Board of Governors unless the context makes clear otherwise.
It is the University’s policy:
that all decisions for the University are taken by persons whose judgement is demonstrably impartial
that Governor and staff conduct is consistent with the University’s legal obligations in respect of promoting the University’s education and research functions fairly and in not allowing a person’s connexion with the University to be operated for private/external gain or advantage or in any other way which is incompatible with serving the University’s best interests and
that disclosure of external interests is encouraged and any conflict will be managed by the University in a way, where practicable, which does not prejudice employment, appointment or publication opportunities.
that all decisions for the University are taken by persons whose judgement is demonstrably impartial that Governor and staff conduct is consistent with the University’s legal obligations in respect of promoting the University’s education and research functions fairly and in not allowing a person’s connexion with the University to be operated for private/external gain or advantage or in any other way which is incompatible with serving the University’s best interests and that disclosure of external interests is encouraged and any conflict will be managed by the University in a way, where practicable, which does not prejudice employment, appointment or publication opportunities.
1 (a) Staff and Governors are personally responsible for identifying any potential, perceptible or actual conflicts of interest relevant to their role for the University.1 (b) Consideration of the potential for conflict should cover the University's spectrum of activities and interests, such as any impact on students, on contracts or contractors, on entities connected with the University, on any of the University's related companies, on funding or University consultancy opportunities and on projects or partnerships associated with the University or with its reputation. Examples are given at Appendix 1.
2 (a) All Governors (the Vice-Chancellor is a Governor ex officio) and the following staff must make an annual return in the form appearing here as Appendix 4 at the start of the academic year declaring their external interests and any material change in them to the Registrar and Chief Operating Officer who is also the Clerk to the Board of Governors:
and the Registrar and Chief Operating Officer who shall make a return to the Vice-Chancellor and to the Chair of the Board of Governors.
2 (b) Failure to complete the annual return, which must be returned as “nil” where no conflict is identified, provides grounds for disciplinary action.
3 (a) Once a staff member has identified a potential, perceptible or actual conflict, they should, without delay, report the circumstances to the Commercial and Knowledge Exchange Director, currently David Hartley, who acts as the nominee of the Registrar and Chief Operating Officer.3 (b) This reporting responsibility applies also to any manager to whom a member of staff discloses a potential, perceptible or actual conflict.3 (c) Members of the Board of Governors must report any potential, perceptible or actual conflict to the Registrar and Chief Operating Officer as Clerk to the Board of Governors on their initial appointment, thereafter annually under paragraph E 2 a), in circumstances where there is a material change in their external interests and also at the start of meetings or meeting items where their conflict is relevant.3 (d) Where a Governor has declared a conflict, the management of this conflict for the University will be conducted by the Registrar and Chief Operating Officer as Clerk to the Board of Governors save where he is part of the relevant conflict in which case the route for management of the conflict will be determined at the time by those Governors not conflicted.3 (e) Where a member of employed staff is also a Governor, they should choose the reporting route for the role (staff or Governor) in which they suspect or know that they are conflicted. Where it is not possible to draw this distinction reliably, they should choose the staff route initially.
4 (a) Once a conflict matter has been reported to him, the Commercial and Knowledge Exchange Director must investigate as he sees fit and must complete a note of his consideration and decision in the form attached as Appendix 2.4 (b) Any manager approached by the Commercial and Knowledge Exchange Director or by an employee concerned about conflict must support proper consideration of the matter, for example by discussing both the likely impact of the potential or actual conflict and the feasible options for conflict management.
5 (a) To complete the record/Register entry, the Commercial and Knowledge Exchange Director will in most cases need to interview the subject of the conflict and quite possibly their line manager and perhaps one or more other colleagues, which may include Human Resources, and subsequently to consider the University's position in order to decide which of the following options best applies:
5 (b) The Commercial and Knowledge Exchange Director shall promptly provide the person to whom the conflict matter relates with a dated record of the decision taken under 5 a) above.
5 (c) Any person not satisfied with a decision made on conflict which falls under 5 a) ii) or iii) above may appeal in writing within one month of the date of the decision to the Registrar and Chief Operating Officer or, where the Registrar and Chief Operating Office is the subject of the decision, the Vice-Chancellor.
The following University policies should also be consulted where relevant to the circumstances: