Declaring interests: policy guidance

This guidance will help you understand who needs to make an annual declaration of interests and how to do this, in line with UCL’s Disclosure of Conflict and Declaration of Interest Policy.

Guidance contents

• Declarations of interest at UCL
• Who needs to make an annual declaration
• What qualifies as an external interest
• Senior staff with no external interests
• Senior staff with interests unchanged from last declaration year
• When to make a submission
• How to declare interests
• Who reviews an annual declaration
• Responsibility for ensuring staff comply with the policy
• Examples of how to apply the policy around declarations of interest
• Differentiating declarations of interest from disclosures of conflict: case study
• Help and support

Declarations of interest at UCL

All Grade 10 staff, Heads of Department, and certain other senior members of staff are required to submit an annual declaration of interests every year through the ‘Declaration of Interest’ system in Inside UCL. (Section 8, UCL Disclosures of Conflict and Declaration of Interest policy).

These declarations contribute to a register of external interests that helps UCL manage and understand the many ways its senior staff engage with the wider world. Declarations demonstrate a commitment to moral and ethical standards and promote transparency across the institution.

Who needs to make an annual declaration

Staff required to submit an annual declaration include:

• all Heads of Division and Heads of Department
• members of staff at grade 10 or above
• persons with a delegated authorisation limit of £75,000 and above
• the Provost
• Vice-Provosts
• the Chief Operating Officer
• all members of the Provost’s senior management team
• directors of subsidiary companies of UCL
• other senior staff as specified by the Provost or any Vice-Provost, from time to time

What qualifies as an external interest

An external interest is where you're involved with any organisation or person not legally associated with UCL. Interests are categorised as:

• business positions (e.g. executive and non-executive directorships, partnerships, ancillary employment in other businesses) 
• appointments (e.g. trustee in charitable organisation, 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

Senior staff with no external interests

If you have no interests to declare, you must still make a submission each year through the system, stating you have 'No interest to declare'.

Senior staff with interests unchanged from last declaration year

If your external interests remain unchanged from last year, you must still update (renew) your previous entry in the system for the current declaration year. 

When to make a submission

The submission year runs from 1 August to 31 July, so you must submit your declaration by 31 July each year at the latest.

However, it’s good practice to declare interests early in the year (on, or soon after, 1 August). If circumstances change, you can update your declaration later in the year. This ensures that your declared interests are always current and that you’re in compliance with the policy. 

How to declare interests

Interests must be declared via the Declaration of Interest system in Inside UCL.

Who reviews an annual declaration

It’s at the discretion of the Chief Operating Officer at UCL to decide who needs access to submissions.

Data will primarily be used for compliance reporting and management information at departmental, faculty and institutional level.

All declarations will be treated in line with GDPR. They will not be shared beyond those who need to see them for oversight and management purposes.

Responsibility for ensuring staff comply with the policy

The following are responsible for making sure relevant staff within their faculty, division or department have made their annual declaration of interests: 

• Deans of Faculties
• Heads of Division
• Heads of Department
• Heads of Vice-Provosts offices
• Heads of Professional Services

Examples of how to apply the policy around declarations of interest

External interests that must be declared annually

As a senior staff member, you must declare the following external interests in your annual declaration of interests: 

• business positions (including in spinout and startup companies)
• remunerated positions
• honorary positions (including honorary appointments at other universities)
• consulting arrangements
• appointments (clinical or other) to NHS trusts
• appointments to funding bodies
• shareholding in a company (covered by Appendix 1 of the UCL Disclosure of Conflict and Declaration of Interest policy)
• being a trustee of a charity
• being a school governor
• appointments to residential management companies
• royalties from books or other activities carried out before joining UCL (if significant, and as covered by Appendix 1 of the UCL Disclosure of Conflict and Declaration of Interest policy)
• receiving gifts (including sponsored travel or accommodation. You must also refer to UCL’s Anti-Corruption and Bribery Policy which deals with receiving gifts in more detail)
• serving on a scientific advisory board (SAB)
• editing a journal or other publication
• leading a learned society
• judging an academic or other significant competition

If there’s potential for conflict to occur between your obligations to UCL and your external interest, you must also disclose it as a conflict of interest.

External interests that do not typically need to be declared

As a senior staff member, you do not routinely need to declare the following external interests in your annual declaration of interests:

• membership of a residents association
• membership of a volunteering group
• membership of a local society
• membership of a learned society
• being an external examiner for a degree programme at another university
• being an external examiner for a doctoral viva at another university
• reviewing submissions for a journal

If there’s potential for conflict to occur between your obligations to UCL and your external interest, you must declare this as an interest and disclose it as a conflict of interest.

Differentiating declarations of interest from disclosures of conflict: case study

In this case study, a senior member of UCL staff is serving as a school governor. The school does not interact with UCL in any way. The senior staff member must therefore declare this role as an interest in their annual declaration of interests.

However, if the school begins working with UCL in a way that creates a conflict (actual, potential, or perceived) between the senior staff member’s duties to UCL and their role as a governor, they must immediately disclose this as a conflict of interest.

This work could include being engaged in research, funding research projects, or receiving applications from the school if the staff member is in a position to influence or engage in the application process.

For as long as the conflict lasts, the staff member must declare this role annually as an interest and ensure that the details of the disclose of conflict (and any mitigating steps) remain current. 

Find out more about conflicts of interest. 

Help and support

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 the ‘Report a problem’ form in Inside UCL. (You can find this by clicking the three horizontal lines in the top left corner of Inside UCL and scrolling down the menu to ‘Report a problem’).

General enquiries about the policy and process should be sent to declareinterests@ucl.ac.uk