Disclosing conflicts of interest: policy guidance

This guidance will help you understand when and how to disclose conflicts of interest, in line with UCL’s Disclosure of Conflict and Declaration of Interest Policy.

Guidance contents

• Conflicts of interest
• Who the policy applies to
• Examples of how to apply the policy
• Disclosing a conflict of interest: staff
• Disclosing a conflict of interest: students
• Finding out if someone has already disclosed a conflict you're aware of
• Subsidiary companies of UCL
• Creating a company as a UCL member of staff or student
• Conflict Management Plans
• Managers' and team leaders' responsibilities
• New starters at UCL
• Consultants/contractors and conflicts of interest
• Recruiting a friend or family member
• Making an annual declaration of interest
• Help and support

Conflicts of interest

Broadly speaking, a conflict can occur when your personal interests, personal relationships or duties to others compete with your obligations to UCL (as a member of staff or student). 

This can include situations where your UCL obligations are likely to be compromised, or may appear to be compromised, by personal gain or gain to your immediate family (or people you have a close personal relationship with).

Examples of conflicts of interest

Conflicts of interest may be financial or non-financial or both (Appendix 1, Disclosure of Conflict and Declaration of Interest Policy).

Financial interest can include pay, commission, consultancy fees, equity interests, debt forgiveness, substantial property, royalties, and intellectual property rights.

Non-financial interest is a benefit or advantage that does not have a financial element. This may include career enhancement, education or professional reputation, and access to privileged information or to facilities.

Potential conflicts can arise when you, members of your family or those you have close relationships with are involved in:

• business positions (e.g. Executive and non-Executive Directorships, partnerships, ancillary employment in other businesses) 
• appointments (e.g. trustee in charitable organisations, school governor, appointment with a funding body or in other organisations)
• consultancies (whether through UCL Consultants or any other route)
• investments (e.g. shareholdings [including spinout companies] or beneficial interests in shareholdings, trusts/nominee companies, other assets or significant sources of income)
• gifts (e.g. reportable gifts such as substantial travel, hospitality or other forms of valuable benefit)
• other personal interests which could constitute a potential conflict of interest situation

This list is not exhaustive, and other situations could constitute potential conflicts.

Examples of what’s not a conflict of interest

Any aspect of your personal and professional identity, including personal belief and internal interests (such as education, profession, reputation, career advancement) are not considered conflicts of interest (Appendix 1,Disclosure of Conflict and Declaration of Interest Policy).

Who the policy applies to

Staff 

Staff covered by the policy are referred to as Relevant Staff. 

Relevant Staff include:

• all employees of UCL
• honorary staff
• emeritus staff
• visiting staff
• contractors and consultants (in circumstances where conflicts have not already been appropriately managed through their own conflict management processes)
• staff and directors of UCL’s subsidiary companies

If any Relevant Staff have a real or potential conflict and need to disclose this, they’re referred to as the Discloser of a conflict (Appendix 3, Disclosure of Conflict and Declaration of Interest Policy).

Students 

Students covered by the policy are referred to as Relevant Students. Relevant Students mean all UCL students undertaking work and training towards a doctoral degree (Appendix 3, Disclosure of Conflict and Declaration of Interest Policy).

If any Relevant Students have a real or potential conflict and need to disclose this, they’re referred to as the Discloser of a conflict.

Roles outlined in the policy: Discloser and Reviewer

There are two distinct roles within the policy (Appendix 3, Disclosure of Conflict and Declaration of Interest Policy), as follows:

Discloser: Any Relevant Staff or Relevant Student who needs to disclose a real, potential or perceived conflict of interest.

Reviewer: The person responsible for reviewing a disclosed conflict and ensuring that there’s a relevant Conflict Management Plan if required. You can find out who would be responsible for reviewing your disclosures under Disclosing a Conflict of Interest below.

Examples of how to apply the policy 

UCL employee working for another organisation 

This could form a conflict of interest, depending on what organisation you work for. If there’s a risk of conflict, it should be disclosed to your Reviewer directly. You should also agree a Conflict Management Plan with your Reviewer.

As examples, if you work at another university and there’s a chance you may be competing for the same grants, or using knowledge gained at one institution to further another, you need to disclose these as potential conflicts.

If you work at a company that could provide services or goods to UCL and you’re involved in the decision-making for this (in either UCL or the other company), you should disclose this as a potential conflict. 

Shareholder in a company

You must disclose shareholdings where there’s potential for conflict to occur between your obligations to the external company and UCL. 

For senior staff making an annual declaration of external interests, you should declare any shareholdings covered by Appendix 1 of the policy.

Member of a residents’ association, volunteering group or local society

Usually you will not need to disclose any interests of this sort. However, where these organisations are applying for funding from UCL, working alongside UCL, or participating in research with UCL, you should disclose a potential conflict.

Being an external examiner for a degree programme at another university

In some exceptional circumstances this could become a potential conflict. So if you’re unsure of whether your external examiner roles could be perceived as, or become, a conflict you should disclose the activity.

For senior staff making an annual declaration of external interests, you do not need to declare this routinely in your declaration.

Royalties from books or other activity carried out before joining UCL

If significant, these should be treated as income streams and you should disclose them in line with Appendix 1 of the policy.

Trustee of a charity, or a school governor 

You do not need to disclose these activities unless the charity or school is working with UCL. This could include being engaged in research, funding research projects, or receiving applications from the school if you’re in a position to influence or engage in the application process.

For senior staff making an annual declaration of external interests, you need to declare this activity in your declaration.

Receiving gifts

Receiving gifts can be seen as a conflict of interest if you’re able to influence decision-making or in a position where the gift could be construed as influencing a decision-making process.
 
It’s therefore vital to ensure that reportable gifts (as defined by Appendix 1 of the policy) are disclosed and your head of department has reviewed these and taken any necessary steps.

You must also refer to UCL’s Anti-Corruption and Bribery Policy which deals with receiving gifts in more detail.

Sponsored travel, or travel where a conference, external organisation or government has paid for your travel

This could form a considerable conflict of interest and must be disclosed.

Your head of department should review this disclosure. They should identify any necessary steps to ensure conflicts arising from accepting sponsorship are managed and avoided wherever possible.

Friends and family 

Close personal relationships with people within UCL are covered by the Personal Relationships Policy.

If you have a relationship with someone outside UCL who has interests that could cause a conflict for you with UCL (for instance, a family member owning equipment or services that UCL may want to purchase), this would be a conflict of interest and should be disclosed.

Disclosing a conflict of interest: staff

Staff should make a conflict of interest disclosure as soon as there’s a risk that a conflict or potential conflict might arise – that is, as soon as you recognise that a conflict might be perceived (section 6.1, Disclosure of Conflict and Declaration of Interest Policy).

Speaking openly about a real or perceived conflict does not negate the need to disclose that interest or conflict through the proper channels.

To record or manage real or potential conflicts, staff should use the ‘UCL Manage Conflicts and Declare Interests’ system, accessed via www.ucl.ac.uk/myhr Detailed instructions on how to use the system are in the user guide.

Who reviews a staff disclosure

For most staff, your head of department or division will review your disclosed conflicts (they’re called the Reviewer in the policy). Within professional services teams, the relevant head of professional services or head of vice-provosts’ office will review conflicts disclosed by staff in their departments (section 6.2, Disclosure of Conflict and Declaration of Interest Policy).

If the person making a disclosure is a head of department, the dean of their faculty will review any disclosed conflicts.

The relevant vice-provosts, the COO or Director of FBA will review conflicts disclosed by deans or heads of professional services functions that relate to their functional area. The Provost will review conflicts disclosed by vice-provosts, the COO or the Director of FBA. The Chair of Council will review conflicts disclosed by the Provost. 

If the person named as the Reviewer also has an interest in the disclosed conflict, it must be referred for review to the next level of authority and, if necessary, a Conflict of Interest Committee can be set up to review a conflict.

For Joint Research Office or clinical trial unit disclosures

Where sponsored clinical research projects are supported by the Joint Research Office (JRO) or one of UCL’s clinical trials units (CTU), disclosure of conflict and developed Conflict Management Plans must be reviewed by the unit before being submitted to your head of department or equivalent for approval. 

It's a requirement for all sponsored clinical researchers to provide information on any potential conflicts of interest when submitting their application for regulatory and NHS REC approval. You can seek advice from the relevant unit.

After you’ve submitted a disclosure

Your disclosure will be made available to your Reviewer (see how roles are outlined in the policy). They’ll assess the potential risk of a conflict of interest and discuss this with you. If appropriate, they’ll put in place a Conflict Management Plan to manage the risks of the identified conflict.
 
This Conflict Management Plan will be saved alongside your original disclosure and should be accessible to both of you.

After the plan is in place, it’s your responsibility to adhere to it. Your Reviewer, or a nominated individual, will be responsible for ensuring you comply with the policy and any Conflict Management Plan put in place.

Your disclosure could be escalated to a more senior member of staff if necessary. This is detailed in ‘Who reviews a staff disclosure’ (section 6.2, Disclosure of Conflict and Declaration of Interest Policy). 

Confidentiality for sensitive conflicts of interest

All disclosures will be treated in line with GDPR.

They will not be shared beyond those who need to see the entry or the Conflict Management Plan in order to review, manage or ensure adherence to the plan. 

Disclosing a confidential conflict

Very occasionally, you might have an interest that you believe may conflict with your work at UCL, but you’re prevented from disclosing specific information on contractual or other grounds.

In these exceptional circumstances, you may choose to disclose the broad category and nature of interest without necessarily naming the body or company concerned. 

This does not remove the duty to disclose a significant conflict of interest to your Reviewer.

Disclosing a conflict of interest: students

Students should make a conflict of interest disclosure as soon as there’s a risk that a conflict or potential conflict might arise – that is, as soon as you recognise that a potential conflict might be perceived.
 
Speaking openly about a real or perceived conflict does not negate the need to disclose that interest or conflict through the proper channels.

To record or manage real or potential conflicts, students should use the ‘UCL Manage Conflicts and Declare Interests’ system, accessed via www.ucl.ac.uk/myhr Detailed instructions on how to use the system are in the user guide.

Who reviews a student disclosure

Your research supervisor will review your disclosed conflicts. They’ll assess the potential risk of a conflict of interest and discuss this with you. If appropriate, they’ll put a Conflict Management Plan in place to manage the risks of the identified conflict (section 6.5, Disclosure of Conflict and Declaration of Interest Policy).

If your research supervisor is also involved in the conflict, your head of department will review your disclosure (section 6.4, Disclosure of Conflict and Declaration of Interest Policy).

After you’ve submitted a disclosure

Your disclosure will be made available to your Reviewer. They’ll assess the potential risk of a conflict of interest and discuss this with you. If appropriate, they’ll put a Conflict Management Plan in place to manage the risks of the identified conflict. 

This Conflict Management Plan should be saved alongside your original disclosure and accessible to both of you. 

After the plan is in place, it’s your responsibility to adhere to it. Your research supervisor will be responsible for ensuring your compliance with the policy and any conflict management plan put in place.

Confidentiality for sensitive conflicts of interest

All disclosures will be treated in line with GDPR.

They will not be shared beyond those who need to see the entry or the Conflict Management Plan in order to review, manage or ensure adherence to the plan. 

Disclosing a confidential conflict

Very occasionally, you might have an interest that you believe may conflict with your work at UCL, but you’re prevented from disclosing specific information on contractual or other grounds.

In these exceptional circumstances, you may choose to disclose the broad category and nature of interest without necessarily naming the body or company concerned. 

This does not remove the duty to disclose a significant conflict of interest to your Reviewer.

Finding out if someone has already disclosed a conflict you’re aware of

Access to individual disclosures of conflict are limited to your Reviewer, and others who may require access for legitimate reasons, such as an HR staff member. 

If you believe someone may not have disclosed a conflict (actual, potential or perceived), you’re required to raise this with the individual’s head of department or equivalent. 

If a disclosure has not been recorded, the head of department should speak to the staff in question directly. Where appropriate, they should require the staff member to disclose the conflict through usual routes.

Subsidiary companies of UCL

Managing implementation and compliance with the policy as a UCL subsidiary company 

The board of directors of each subsidiary company of UCL is responsible for ensuring the implementation of and compliance with this Policy by staff and students working at the relevant subsidiary company.

The boards of directors will also ensure that staff and students working at the relevant subsidiary company are made aware of this Policy and related guidance. 

Submitting an annual declaration of external interests

As senior staff, the directors of UCL’s subsidiary companies are required to submit an annual summary of their external interests.

Creating a company as a UCL member of staff or student

UCL recognises the importance of interactions and relationships between UCL employees and students and companies for the purposes of research, teaching and innovation.

If you set up a company (e.g. a startup or spinout) that intends to collaborate with UCL staff or students, you must disclose your interests in relation to the company. This includes any potential conflicts of interest.

Any UCL staff or students who have a significant relationship with the company must also disclose these interests.

Disclosure must be made to the relevant head of department in accordance with the UCL Disclosure of Conflicts and Declaration of Interests Policy. An appropriate Conflict Management Plan must also be developed and managed.

A collaboration agreement or agreements may also need to be in place between UCL and the company to govern use of UCL IP, equipment or facilities and related matters.

Conflict Management Plans (CMPs)

Conflicts of interest (potential or real) should be managed first via a Conflict Management Plan that sets out an agreed strategy to reduce, mitigate, or remove a disclosed conflict. 

The Conflict Management Plan might include review dates and responsibilities of Discloser, Reviewer and others. It might also identify any options for amendment that may be required in the future. 

There are several strategies that may be appropriate to a disclosed Conflict Management Plan.

These may include (but are not limited to):

• not taking part in discussions of certain matters
• not taking part in decisions in relation to certain matters
• referring to others certain matters for decision
• resolving not to act as a particular person’s supervisor
• divesting or placing in trust certain financial interests
• publishing a notice of interest
• standing aside from any involvement in a particular project
• declaring an interest to a sponsor or third party

Developing and approving a Conflict Management Plan 

To support UCL individuals developing CMPs, we've produced guidance on creating a Conflict Management Plan and a general Conflict Management Plan template.

It’s highly recommended that these two resources are used together to develop an effective CMP.

Managers’ and team leaders’ responsibilities

As a manager or team leader, you should ensure all Relevant Staff and Relevant Students you manage or oversee are aware of the policy and have disclosed any potential, perceived or real conflicts of interest as soon as they arise.

Once you’re aware of conflicts of interest, you should ensure the member of staff and/or student has disclosed it formally. 

To understand your roles as a manager and team leader, please refer to ‘Who reviews a staff disclosure’ and ‘Who reviews a student disclosure’ sections.  

New starters at UCL

For new Relevant Staff and Relevant Students, training will be a component of the induction process. 

Heads of department and other managers will be provided with appropriate training to support their roles and responsibilities. 

All new and existing staff are required to complete the training on the Declaration of Conflicts and Disclosure of Interests Policy.

Ongoing engagement with any external interest

It’s highly unlikely you’d be asked to stop engaging in an activity or interest you held before joining UCL. 

However, if there’s a potential risk that the existing interests may conflict with UCL’s interests, you must disclose these and work with your head of department to put a Conflict Management Plan in place.

Consultants/contractors and conflicts of interest

Consultants and contractors must disclose any conflicts of interest when they begin working at UCL, unless they can demonstrate evidence of internal conflict of interest processes to an adequate standard.

For example, if the consultancy or contracting firm has their own conflict of interest processes to identify and mitigate against potential conflicts that could arise from working with UCL, then we would not need them to disclose interests to UCL.
 
We would normally expect self-employed individuals to disclose interests.

Large companies would not be expected to disclose interests where their internal processes have already managed and mitigated against them.

Recruiting a friend or family member

Recruitment is covered by HR policies, in particular the Recruitment and Selection Policy, and all panel members are required to state any relationship with applicants prior to interview. This should then be managed through HR processes.

As this does create a conflict of interest, it may be that a Conflict Management Plan needs to be developed, or you may be asked to step aside from the recruitment process to remove the conflict and ensure a fair recruitment and selection process.

Making an annual declaration of interest

Grade 10 staff, Heads of Department, and certain other senior members of staff are also required to submit an annual declaration of interests every year.

Help and support 

For step-by-step guidance on disclosing a conflict on the system, see our system user guide.

For help understanding UCL's Disclosure of Conflict and Declaration of Interest Policy, access our online training.

Queries about the system should be sent via RemedyForce. 

General enquiries about the policy and process should be sent to: 

• discloseconflicts@ucl.ac.uk (for disclosure of conflicts, including Conflict Management Plans) 
• declareinterests@ucl.ac.uk (for declaration of interests)