UCL Policy on Conflicts of Interest and Declarations of Interest

This policy sets out requirements for staff and doctoral students to identify, disclose and manage conflicts of interest; and declare external interests.

To help you understand and implement this policy, you can access guidance on SharePoint.

You can also download a Word version of the policy.

1. Purpose

1.1 UCL encourages its community to engage in a wide variety of external activities and considers these essential to creating impact, knowledge exchange, and public benefit. However, these activities need to be managed appropriately.

1.2 In line with our values, UCL is committed to ensuring that the highest levels of integrity apply in all areas of our operation and that all our activities are conducted in an honest and transparent manner.

1.3 The purpose of this Policy, and the related conflict of interest and declaration of interest guidance, training, and UCL System, is to provide a framework for: (1) identifying, disclosing and managing conflicts of interest; and (2) declaring external interests. Ensuring that such interests are identified, disclosed and managed, and that Eligible Staff are declaring their external interests each year, is vital for promoting transparency across the institution.

1.4 This Policy:

Gives Staff and Doctoral Students the information they need to be able to identify actual, perceived or potential conflicts of interest (see Section 4);
Requires Staff and Doctoral Students to disclose conflicts of interest (see Section 5);
Sets out requirements for managing conflicts of interest (see Section 6);
Sets our requirements and defines appropriate hierarchies for reviewing conflicts of interest and Conflict Management Plans (see Section 7);
Sets out requirements for declarations of external interests by Eligible Staff (see Section 8); and
Sets out requirements for institutional officers to support policy implementation (see Section 9).

1.5 This Policy does not cover the declaration of personal relationships within the UCL community. This is addressed in the UCL Personal Relationships Policy.

2. Definitions

2.1 Conflict Management Plan: As defined in section 6.1 of this Policy.

2.2 Eligible Staff: As defined in Section 8.3 of this Policy.

2.3 External Interest: As defined in Section 8.2 of this Policy.

2.4 Staff: All employees of UCL, and other individuals working at UCL, including agency workers, honorary staff, emeritus staff, visiting staff, contractors and consultants.

2.5 Doctoral Students: All individuals who are undertaking the programme of work and training that will, if pursued to the required standard, lead to the award of a doctorate and who are registered with UCL, via Student and Registry Services, for their degree.

2.6 Reviewer: An individual responsible for reviewing and managing a conflict of interest under Section 7 of this Policy.

2.7 Risk: Financial, legal, regulatory and reputational risk.

2.8 Subsidiary Company: Subsidiary company has the meaning given in s1159 Companies Act 2006.

2.9 UCL System: The system which holds the details of all disclosed conflicts of interest and all declared External Interests.

3. Scope

3.1 This Policy applies to Staff and Doctoral Students.

3.2 Staff and students who are also members of UCL Council and any other UCL committee will also need to comply with the relevant declaration of interest requirements of those bodies.

4. Identifying Conflicts of Interest

4.1 Staff and Doctoral Students are responsible for identifying situations in which they have a conflict of interest or might reasonably be seen by others to have a conflict of interest.

4.2 A conflict of interest exists when a duty owed by Staff or a Doctoral Student to UCL conflicts, or may conflict, with:

(1) a personal, financial or other interest, duty, or loyalty owed by that member of Staff or Doctoral Student to another organisation or person; or
(2) an interest of a Connected Person, being a person with an interest external to the university with whom Staff or a Doctoral Student has a personal or business connection. This can include, but is not limited to:

family members (e.g. spouse/partner, sibling, parent, grandparent, child or grandchild);
friends;
collaborators (e.g. in other universities or charities); and
business partners.

4.3 Interests can include:

(1) roles within external organisations (e.g., directorships, partnerships, trusteeships, ancillary employment, voluntary, honorary, or consultancy positions, including within subsidiaries, spinouts and other companies and charities associated with UCL);
(2) investments in, or from, external organisations (e.g., shareholdings);
(3) commission, gifts and other financial and non-financial benefits (e.g., subsidised travel).

4.4 A conflict of interest can be actual, perceived or potential.

(1) An actual conflict of interest is one which clearly conflicts with an individual’s objectivity and/or ability to discharge their duty to UCL.
(2) A perceived conflict of interest is one which a reasonable person would consider likely to conflict with an individual’s objectivity and/or ability to discharge their duty to UCL.
(3) A potential conflict of interest is one which could develop into an actual or perceived conflict of interest.

4.5 Interests may be financial or non-financial.

(1) financial interest refers to anything of non-trivial monetary value (e.g., pay, commission, consultancy fees, equity interests, discounts and fee waivers, forgiveness of debt, property, royalties, and intellectual property rights).
(2) non-financial interest refers to any non-financial benefit or advantage (e.g. enhancement of an individual’s career, education or professional reputation; access to privileged information or facilities; benefits in kind).

5. Disclosing Conflicts of Interest

5.1 Staff and Doctoral Students must disclose any actual, perceived or potential conflict of interest:

(1) as soon as such actual, perceived or potential conflict of interest arises or becomes known;
(2) in accordance with the Reviewer escalation hierarchy set out in Section 7 of this Policy; and
(3) via the UCL System.

5.2 Staff and Doctoral Students must disclose conflicts of interest in accordance with the Level of Authority Escalation Hierarchy (set out in Section 7).

5.3 If the Reviewer in the first level of the Level of Authority Escalation Hierarchy is involved in the conflict, Staff or Doctoral Students must disclose the conflict to the next level in the Level of Authority Escalation Hierarchy.

5.4 Staff and Doctoral Students must provide accurate and complete information when disclosing any actual, perceived or potential conflict of interest, and identify any information which is confidential as part of the disclosure.

5.5 Staff and Doctoral Students must immediately notify the relevant Reviewer if there is a conflict between this Policy and the policies and/or the contractual obligations owed to an external organisation with which the individual is involved.

5.6 If Staff or Doctoral Students are concerned that another member of Staff or a Doctoral Student may have an undisclosed conflict of interest, they must raise this with the Head of Department (or equivalent) of the member of Staff or Doctoral Student.

5.7 If a Head of Department (or equivalent) becomes aware that a member of Staff or a Doctoral Student in their functional area has an undisclosed conflict of interest, they must ensure that the member of Staff or Doctoral Student discloses this as soon as possible in accordance with this Policy.

5.8 The requirement to disclose conflicts of interest is an ongoing one and Staff and Doctoral Students must review and disclose or update disclosures of conflicts of interest on a continuing and ongoing basis.

5.9 Failure to disclose a conflict of interest in a timely fashion may constitute misconduct and may be referred to the appropriate university disciplinary process for action. Timely in this context means in sufficient time to allow the conflict and associated risks to be managed as described in Section 6.

5.10 If Staff or Doctoral Students are unsure about whether they have a conflict of interest, they must treat the matter as if it were a conflict of interest and disclose it in accordance with this Policy.

6. Managing conflicts of interest

6.1 A Conflict Management Plan is required for any conflict of interest under Section 4 of this Policy. By setting out an agreed strategy to reduce, mitigate or remove a conflict of interest, such a plan ensures that the Risks presented by a conflict are mitigated.

6.2 Staff and Doctoral Students must:

(1) develop a Conflict Management Plan to the satisfaction of their Reviewer in accordance with the Level of Authority Escalation Hierarchy (set out in Section 7), and;
(2) manage their conflicts of interest in accordance with that plan. Guidance on developing, implementing and reviewing Conflict Management Plans is set out in the supporting policy guidance.

6.3 Reviewers must support the development of a Conflict Management Plan for conflicts of interest disclosed to them and review its implementation in accordance with the level of authority and escalation requirements in Section 7.

6.4 The line manager of the staff member, or the supervisor and Departmental Graduate Tutor (or equivalent) of the Doctoral Student, must support the development and review of a Conflict Management Plan, when:

(1) the Reviewer is not the line manager or supervisor or Departmental Graduate Tutor (or equivalent) of the Staff member or Doctoral Student;
(2) the line manager or supervisor or Departmental Graduate Tutor (or equivalent) of the Staff member or Doctoral Student is not involved in the conflict of interest, and;
(3) disclosure of the conflict of interest would not breach any duty or obligation of confidentiality.

6.5 A Conflict Management Plan must include all relevant information, an assessment of any conflict of interest, and an agreed strategy for managing the conflict of interest.

6.6 The choice of strategy for managing a conflict of interest in a Conflict Management Plan must take into account:

(1) all relevant information;
(2) the nature of the conflict;
(3) the complexity of the situation; and
(4) the level of Risk posed to UCL.

6.7 Staff and Doctoral Students must not take part in any UCL activity or decision making in which their duty to UCL could be compromised by a conflict of interest, unless the conflict has been reviewed and is being managed in accordance with this Policy.

6.8 Conflicts of interest must be managed in accordance with a Conflict Management Plan or removed as soon as possible and no later than two (2) months after the initial disclosure, and in accordance with Section 6.7.

6.9 Further guidance on developing, implementing and reviewing Conflict Management Plans is set out in the supporting policy guidance.

7. Reviewer Responsibilities, Level of Authority and Escalation for Conflicts of Interest

7.1 Reviewers must review conflicts of interest disclosed to them as soon as possible and in accordance with the timelines set out in paragraph 6.8, ensuring that they understand:

(1) the nature of the conflict of interest;
(2) the nature of the Risks it poses.

7.2 Reviewers must discuss the disclosure with the line manager of the staff member, or the supervisor and Departmental Graduate Tutor (or equivalent) of the Doctoral Student, when:

7.3 Disclosures of conflicts of interest must be reviewed in accordance with the level of authority specified in the Level of Authority and Escalation Hierarchy below.

7.4 Conflict Management Plans must be developed and reviewed in accordance with the level of authority specified in the Level of Authority and Escalation Hierarchy below.

7.5 The Reviewer must escalate a review of a disclosed conflict of interest or the development and review of a Conflict Management Plan to the next level of authority in the Level of Authority and Escalation Hierarchy below when:

(1) the Reviewer is involved in the interest giving rise to the conflict;
(2) the issues are too complex for the Reviewer to assess; or
(3) the interest presents significant Risk to UCL.

Level of Authority and Escalation Hierarchy

1. Head of Department (or equivalent)

Review disclosures and develop and review Conflict Management Plans for conflicts of interest submitted by Staff and Doctoral Students in their departments.

2. Deans

Review disclosures and develop and review Conflict Management Plans for conflicts of interest:

submitted by Heads of Department (or equivalent) in their faculty;
and in specific cases:
- submitted by Staff and Doctoral Students in their faculty;
- escalated by Heads of Departments (or equivalent) in their faculty.

3. Vice-Provosts and Vice-Presidents

Review disclosures and develop and review Conflict Management Plans for conflicts of interest:

submitted by Deans in their functional area;
and in specific cases:
- submitted by Heads of Department (or equivalent) in their functional area;
- submitted by Staff and Doctoral Students in their functional area;
- escalated by Deans in their functional area;
- escalated by Heads of Departments (or equivalent) in their functional area.

4. President & Provost

Review disclosures and develop and review Conflict Management Plans for conflicts of interest:

submitted by Vice-Provosts and Vice-Presidents;
and in specific cases:
- submitted by Deans;
- submitted by Heads of Department (or equivalent);
- submitted by Staff and Doctoral Students;
- escalated by Vice-Provosts and Vice-Presidents.

If required, convene an advisory group to support the review and management of disclosed conflicts of interest.

5. Chair of Council

Review disclosures and develop and review Conflict Management Plans for conflicts of interest:

submitted and/or escalated by the President & Provost;
and in specific cases:
- submitted by Vice-Presidents and Vice-Provosts.

8. Annual Declaration of External Interests for Eligible Staff

8.1 In addition to the requirement to disclose actual, perceived or potential conflicts of interest under Section 5 of this Policy, Eligible Staff must submit an annual declaration of their External Interests in the UCL System.

8.2 External interests means holding a remunerated, honorary, visiting or voluntary position in, or having a material financial interest in, or having a consulting arrangement with any person or organisation which is not legally associated with UCL.

8.3 The following individuals are Eligible Staff for the purposes of this Policy:

(1) all members of staff at Grade 10 or above;
(2) all other Heads of Division and Heads of Department;
(3) all other members of staff with a delegated authorisation limit at the same level or above Heads of Department;
(4) any other staff as may be specified by the Provost or any Vice-Provost or Vice-President, from time to time.

8.4 Eligible Staff must:

(1) provide accurate and complete information when submitting their declaration of External Interests, including when confirming that they have no external interests by making a nil return; and
(2) ensure that their declaration of External Interests is up to date at all times; and
(3) make a conflict of interest disclosure as well as a declaration of interest if the external interest presents an actual, potential or perceived conflict.

8.5 Eligible Staff members must immediately notify the relevant Reviewer if there is a conflict between the requirements to declare External Interests under this Policy and the policies and/or the contractual obligations owed to an external organisation with which the Eligible Staff member is involved.

8.6 Failure to declare and keep up to date the declaration of interests may constitute misconduct and may be referred to the appropriate university disciplinary process for action.

9. Responsible Institutional Officers

9.1 The following institutional officers must actively promote and support policy compliance:

(1) The President & Provost;
(2) Vice-Provosts;
(3) Vice-Presidents;
(4) Deans;
(5) Heads of Division;
(6) Heads of Department;
(7) Heads of Vice-Provosts Offices; and
(8) Heads of Professional Services.

9.2 The Executive Director of Innovation & Enterprise is the delegated responsible officer for overall support of this Policy.

10. UCL System to implement this Policy

10.1 The Vice-President (Operations) is responsible for establishing and maintaining the UCL System, in order to implement the disclosure and declaration requirements under this Policy.

11. Data ownership and management

11.1 The Disclosure of Conflict and Declaration of Interest data is held in accordance with UCL's Data Governance Operating Model.

12 Review of the UCL Policy on Conflicts of Interest and Declarations of Interest

12.1 Research, Innovation and Global Engagement Committee is responsible for reviewing annually the implementation of the UCL Disclosure of Conflict and Declaration of Interest policy and making recommendations to the University Management Committee.

12.2 This Policy will be reviewed in the light of guidance on best practice issued by outside bodies and internal institutional requirements as required, but no less than once every three years.

13 Non-compliance

13.1 Any breach or suspected breach of this policy may be investigated and treated as a disciplinary matter.

14. Related Policies, Procedures, and Guidance

14.1 This Policy relates to, and interacts with, other UCL Policies, Procedures and Guidance. Staff and Doctoral Students must ensure that they familiarise themselves with all those applicable to their role and activities:

Document history

1 August 2020: The Policy was published.
20 January 2026: The Policy was substantially revised.