Conflict of interest
In an environment like The University of Sheffield it is inevitable that from time to time, actual or potential conflicts of interest will arise as a result of the intersection of University activities and personal relationships, financial/commercial or research interests. The majority of these issues are positive and can be simply and appropriately managed with steps to ensure transparency and clarity of the circumstances.
At the University of Sheffield we expect all members of staff to approach conflict of interest issues in accordance with the Nolan principles, which are the 7 principles for Standards in Public Life (selflessness, integrity, objectivity, accountability, openness, honesty and leadership) in accordance with the University's Code of Ethics.
To help identify your responsibilities in the management and recording of conflicts of interest, we have devised a training course for all staff to complete. This training is available from the link on the right, and should take about 5-10 minutes to complete.
|What is a conflict of interest?||
A conflict of interest may exist if circumstances reasonably create a risk that your professional judgement or decision making may be unduly influenced by other interests outside of your University activities. The test is not whether you are actually influenced, but whether there is either the potential for this, or that it could reasonably be perceived that way.
You should avoid wherever possible any situations where you or the University could be perceived to have acted dishonestly or in a way which constitutes a conflict of interest between your various activities or professional and personal relationships. Where potential conflicts are identified, you must be open in declaring them and taking prompt action to mitigate and manage them. Even where you act with complete integrity and neutrality, action is needed to protect you and the University from potential reputational damage and to ensure good governance.
|Types of conflict of interest||
The varied and broad range of the University’s activities makes it impossible to give an exhaustive list of potential conflicts of interest. Conflicts may broadly fall into the following areas and detailed policies and information apply in each case. Illustrative examples are given for guidance.
Financial or commercial
Conflicts of interest may relate to financial or other external/commercial arrangements, for example: shares, share options, equity interests, royalty income, directorships, spin-out companies, additional external employment, consultancy arrangements, contract management, commercialisation of research interests, offering paid private tuition to students on a course you teach, intellectual property agreements) etc.
Please see Section 25 of the University's Financial Regulations for more information.
Conflicts may also potentially arise in relation to personal (friendship or romantic) or family relationships which could impact on teaching, student supervision, staff line management arrangements or involvement in processes such as procurement, recruitment, promotion, or disciplinary/grievance/capability/other procedures. You should be aware that the relationship in question may be your own or that of a close family member/partner (for example where your access to information or knowledge could be seen to confer an advantage on your family or other connected individual).
Please see the University's Personal Relationship Policy for more information.
In addition to conflicts relating to commercialisation of research and directorships etc, conflicts may relate to non-financial benefits or enhancement of career, professional standing or education, Intellectual Property Rights, or perceptions that a benefit may accrue from a particular outcome or timing of research findings which are under your influence. You should be alert to potential conflicts which may arise from work on external committees such as research council committees, editorial boards, peer review panels etc.
Please see Research Services' guidance on Good practices in handling conflicts of interest
|Governance of conflicts of interest||
In keeping with good governance practice, potential conflicts of interest must be declared as they arise or are identified, and individuals and the University must take the appropriate action to manage and mitigate these conflicts. We now have an annual process for all staff to declare and update their individual Register of Interests entry which is held securely and confidentially within departments. This is fundamental good governance practice for the University. It is also in the interests of individuals and departments to ensure that conflicts of interest are managed, and to avoid the credibility or reputation of either individuals or the University being brought into question.
The obligation to declare and manage conflicts of interest is continuous and ongoing, as circumstances may change and develop within the year.
All members of staff of the University are required to recognise real or potential conflicts of interest and to take the necessary action to report and ensure conflicts are avoided or properly managed. Members of staff serving on the Council, the Senate, UEB or any of their respective commitees or sub-groups, and senior staff with delegated decision making authority should also refer to the Conflicts of Interest in Decision Making procedure
Certain senior staff (including Council and UEB members, Heads of Department, Professional Services Directors and staff on University-level committees) are required to declare relevant personal, business and other interests in a separate annual process to produce the institutional Register of Interests, which is managed by the University Secretary to discharge specific regulatory and audit requirements.
If you are an individual who has identified a circumstance which could constitute a conflict of interest, or importantly, which could reasonably be perceived to do so even if it does not actually, you will need to do the following:
The Head of Department (or relevant more senior officer) must be satisfied that the steps agreed to manage the conflict of interest are appropriate and proportionate to protect the reputation and integrity of the individual, the department and the University as a whole.
All staff should complete the conflict of interest training, linked to the right.
|Head of Department responsibilities||
Within Faculties and Professional Services departments, Heads of Departments are responsible for ensuring that a local Register of Interests is maintained as part of good governance. It should be reviewed and updated annually to ensure it is current, comprehensive and addresses potential conflicts as fully as possible. A template Register of Interests is available as a download from the right of this page.
Following a discussion with a staff member about real or potential conflicts of interest, it is good practice to confirm the outcomes of the conversation in writing. A template letter is provided as a download on the right of this page.
Policy on Gifts and Hospitality to and from external parties – Financial Regulations Supplementary Information