Conflicts of Interest

Good governance in public sector organisations recognises the need for having arrangements in place to prevent, counter and deal with potential conflicts of interest. UKRI has no reason to believe that conflicts of interest undermine decision making but UKRI must be vigilant about the risk and have appropriate policies and plans in place. It is important in this context that we guard against the perception of impropriety as well as the reality. We must be able to withstand both internal and external scrutiny.

Definitions

UKRI defines a conflict of interest as a set of circumstances that creates a risk that an individual’s ability to apply judgement or act in one role is, or could be, impaired or influenced by a secondary interest. Even a perception of competing interests, impaired judgement or undue influence may be damaging to UKRI’s reputation.

Generally conflicts might occur if individuals have for example:

  • a direct or indirect financial interest
  • non-financial or personal interests
  • competing loyalties between an organisation they owe a primary duty to and/or some other person or entity.

The existence of an actual, perceived or potential conflict of interest does not necessarily imply wrongdoing on anyone’s part. However, any private, personal or commercial interests which give rise to such a conflict of interest must be recognised, disclosed appropriately and either eliminated or properly managed. Reporting, recording and managing potential conflicts effectively protects staff and can help to generate public trust and confidence.  

Examples of Conflicts of Interest

Financial interests

This is where an individual receives or may receive a direct financial benefit from the consequences of the awarding of funding, for example:

  • a director, including a non-executive director, or senior employee in an organisation which is doing, or which is likely, in receipt of funding or possibly seeking to obtain funding
  • a shareholder (or similar ownership interests), a partner or owner of a private or not-for-profit company which is doing, or which is likely, or possibly seeking to obtain funding
  • a shareholder of a Research Council related start up, that the Council (UKRI) has shares
  • a management consultant for a business/individual
  • in receipt of secondary income from an business/individual
  • in receipt of any payments (for example honoraria, one-off payments, day allowances or travel or subsistence) from an organisation possibly seeking to obtain funding.

Indirect financial interests

This is where an individual has a close association with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision (as those categories are described above) for example:

  • spouse / partner
  • close relative (e.g., parent, grandparent, child, grandchild or sibling)
  • close friend
  • business partner
  • a financial relationship (e.g. pension) with a business/individual seeking to obtain funding.

Non-financial professional interest

This is where an individual may obtain a non-financial professional benefit from the consequences of a funding award, such as increasing their professional reputation or status or promoting their professional career. This may, for example, include situations where the individual is:

  • an advocate for a particular group or
  • a member of a particular specialist professional body.

Non-financial personal interests

This is where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit. This could include, for example, where the individual is:

  • a voluntary sector champion for business/individual
  • a volunteer for business/individual or
  • a member of a lobby or pressure group with an interest research or development.

Indirect interests

This is where an individual has a close association with an individual  who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision (as those categories are described above) for example, a:

  • spouse / partner
  • close relative (e.g., parent, grandparent, child, grandchild or sibling)
  • close friend
  • business partner.

Roles with heightened risk in relation to perceived conflicts of interest

In the list below we have provided some guidance on roles that have a perceived higher risk factor in relation to perceived conflicts of interest. In these roles a form should be filled even if no perceived conflict exists (i.e. a nil return):

  • Procurement – particularly those roles responsible for administering tenders, supplier decisions and contract terms
  • Grant awards – particularly those administering and supporting grants panels
  • Contracting – including those determining contract terms or financial terms, particularly in relation to estates contracts and commercial contracts or
  • Board and Council appointments - particularly those in administering and supporting boards or councils.

This list should not be perceived as exhaustive, if other specific roles exist that have a perceived higher risk factor then please ensure a declaration is submitted (including nil returns).

Documents

Our policy requires our senior leaders to declare any interests that could be (or be perceived as) a conflict in any discussions, decisions or actions that could risk the impression that UKRI have acted improperly. These registers are updated annually or when an individual requires an amendment to be made to their details: