Close
This page includes a step-by-step process to help you identify if you have a conflict of interest and three case studies contextualising conflicts.
Do I have a conflict of interest?
This process will help you consider if you have any potential, perceived or actual conflicts of interest.
Step 1
As conflicts can arise from your individual external interests, consider whether you:
- have a role with any external organisations (including voluntary, honorary, visiting, and consultancy positions)?
- have any other external interests? For example:
- Have you received any gifts such as subsidised travel or a gift that’s enhanced your career?
- Do you have significant investments, shareholdings, or material financial interests in another organisation?
- Are you in receipt of significant royalties from a book or other activity?
A conflict can also arise from the people you know and the way you interact with them in your role at UCL. Consider who’s in your network, including:
- family
- friends
- other individuals you have a close relationship with
Do any of these individuals work, volunteer, or have interests in sectors that could bring them into contact with your activities at UCL?
Remember that conflicts can be financial, non-financial, or a combination of both. They can also be actual, potential, or perceived - and can arise at any time.
Step 2
Consider how your contacts and external interests could overlap and compete with your duties to UCL. Touchpoints between your work at UCL and your external interests and contacts can include (but are not limited to):
- staff and students (e.g. if you involve UCL staff or students in an external company or charity you have an interest in, including as employees, volunteers, or on placements)
- intellectual property (e.g. if you’re developing intellectual property for an external company that’s based on IP that you developed as part of your work at UCL)
- resources and infrastructure (e.g. if you use UCL’s specialist IT infrastructure to benefit a charity in which your serve as a trustee)
- bids and grants (e.g. if you’re involved in writing or advising on competing bids from UCL and another university for grants or funding)
- personal relationships (e.g. if your partner works for a Research Council that you are applying for funding from, or if your friend works for a company that collaborates with UCL)
Even if there’s no current conflict, is it easy to foresee how a conflict of interest could arise – or be perceived as arising – from your connection with them?
Remember that appearance is important here; you should disclose anything that could reasonably be perceived as a conflict by someone else, as well as any actual and potential conflicts.
Step 3
Ask yourself: would a reasonable person consider that my objectivity is likely to be compromised by this external interest?
Could my reputation – and the reputation of my colleagues and UCL at large – be compromised or perceived as being compromised by this external interest?
If you’re uncertain whether or not your external interest is a conflict, you should discuss this with your Head of Department (or equivalent) as soon as possible.
Step 4
If you think your external interest is a conflict (whether actual, potential, or perceived) you must disclose it as soon as possible. Having a conflict of interest doesn’t imply wrongdoing, but it’s essential that conflicts are disclosed and managed to mitigate the risks and protect everyone involved.
Step 5
Take some time at a few points every year to see if anything has changed that could now give rise to a conflict. It’s important to remember that conflicts of interest can arise at any time and should be reported as soon as they arise.
Conflict of interest case studies
Case study 1: Spinout shareholder
Jane is a researcher at UCL who is also a director and shareholder of a spinout company set up to commercialise ideas arising from her research.
This spinout company wants to use some of the UCL equipment in Jane’s research group’s laboratory.
Jane has a conflict of interest because the spinout – and by extension Jane herself – will benefit from access to the UCL’s equipment. This means she cannot make appropriate judgements about UCL’s interactions with the spinout, including the terms on which the spinout accesses UCL’s equipment.
Jane must develop and implement a conflict management plan to mitigate the risks arising. Among other mitigations, the plan should include steps around Jane removing herself from discussions and decision-making at UCL when deciding pricing and prioritisation of equipment that the spinout could benefit from.
Case study 2: School governor
Michael is a UCL staff member who’s recently become a school governor for the local school.
In Michael’s role at UCL, he takes part in interviews for the Medical School. This year students from the school at which he’s governor have applied and been invited to interview.
Michael must develop and implement a conflict management plan to mitigate the risks arising. Among other mitigations, the plan should outline steps around informing relevant people about the conflict of interest and not taking part in any interviews or decision-making that could impact students from the school.
Case study 3: Tendering
Juan is a UCL staff member whose partner runs a company supplying office furniture.
Juan’s department is about to start a new tender process to buy new office furniture and Juan’s role at UCL means they can influence the choice of supplier. Juan’s partner’s company could, in theory, supply the type of furniture required.
Due to this conflict of interest, however, Juan cannot make an objective decision about who should win the bid if his partner’s company responds to the tender request.
Juan must develop and implement a conflict management plan to mitigate the risks arising. Among other mitigations, the plan should include steps around Juan removing himself from discussions and decision-making at UCL that could result in a commercial contract with his partner’s company.