Declarations of Interest Policy
Policy owner: University Secretary and Chief Compliance Officer
| Version | effective from | amendments | equality analysis | stakeholders consulted | approval date | author | date for review |
|---|---|---|---|---|---|---|---|
| V.1.0 | 01.04.2020 | Education & Experience Committee University Executive Board University Research & Ethics Committee | 2020 | Tristan Foot (Acting University Secretary) | |||
| V2.0 | 06.05.2025 | 23 May 2025 | University Executive Board Governance & Search Committee Ethics & Advisory Committee | May 2025 | Jim Benson (University Secretary and Chief Compliance Officer) |
1. Rationale
1.1. Policy sets out the requirements by which governors and staff must comply by declaring interests they may have that conflict with those of the University or have the potential to conflict.
1.2. The Declaration of Interests Policy of the University of East London brings together the conflict of interest elements from a range policy and procedures. This includes the explicit terms of the contracts of employment for all staff, Financial Regulations and the Personal Relationships Policy.
1.3 The University does not intend that this policy should deter staff from undertaking external activities in the course of their professional responsibilities e.g. engagement with relevant professional associations, external examining, delivering conference papers, public lectures etc. For the most part such activities are an integral part of an academic role. However, all external activities should be declared, whether paid or unpaid and, where necessary, agreed in line with this policy.
1.4 The underlying premise of this policy is that governors and staff have a duty to manage conflicts of interest, and a responsibility to identify and disclose actual, potential or perceived conflicts between their personal, family, pecuniary or business interests and their professional responsibilities to the University.
1.5 The Policy provides a framework to protect the University, governors and employees through the management of conflicts of interest. The responsibility to disclose and manage conflicts rests with individuals, governors and staff must take their responsibilities seriously and operate on the basis of full disclosure. The University regards declaration of interests as an extension of its commitment to the Nolan Principles on the standards expected of those in public life.
1.6 The University Secretary will be able to offer advice on request but this does not negate the personal responsibility to disclose and manage conflicts of interest. The policy provides advice on what to declare and there is a guidance note at the end. Governors and staff should be careful not to determine themselves that certain activities do not represent a conflict of interest.
2. Scope of the policy
2.1 This Policy applies to all governors and staff (including fixed-term and temporary and hourly-paid).
2.2 The declaration of interests by members of the Board of Governors is covered by the Bye-Laws and Code of Conduct for Governors. The Register of Interests of all members of the Board, including those of UEB members is retained by the University Secretary and may, as legally required, be published in the annual financial statements or on the University’s website.
3. Related policies
3.1 Governors and staff should also ensure that they abide by the following:
- The Ethical Framework
- Financial Regulations
- Personal Relationships Policy
- Anti-Bribery and Corruption Policy (incorporating the Gifts and Hospitality Policy)
- Intellectual Property Policy
- Staff Disciplinary policy
- Public Interest Disclosure
4. Summary principles
4.1 This policy is based on the following principles:
- The Committee of University Chairs (CUC) Guide for Members of Higher Education Governing Bodies in the UK states that the governing body is responsible for ensuring that clear procedures are in place for managing conflicts of interest. This policy contributes to the delivery of these objectives in providing a framework of responsibilities and reporting by which staff and governors disclose interests which may conflict with those of the University. It is important to note that conflicts of interest are inevitable, and the University’s approach is to ensure that they are appropriately managed, rather than seeking to avoid situations in which they might arise.
- Governors have a duty to manage conflicts of interest, and a responsibility to identify and disclose actual, potential or perceived conflicts between their personal, family, pecuniary or business interests and their professional responsibilities to the University.
- All employees have a responsibility to further the interests of the University; this is implied as part of the employer/employee relationship.
- There is a duty of faithfulness owed by the employee to the employer by virtue of the employment relationship which requires the employee not to act against the interests of the employer.
- All employees have a duty to make a declaration of interests in accordance with this policy at least annually, to notify their line managers of their interests and to seek permission from UEB where they are undertaking external activities.
- Employees must declare any gifts or hospitality in line with section 10 of this policy and in accordance with the Financial Regulations. If an employee’s actions or decisions made during the course of their employment
are considered to be motivated by personal gain including undertaking work that is in conflict with the requirements of their contract or failing to declare interests, the University is entitled to take disciplinary action against the employee (which may result in dismissal).
5. Conflict of interest
5.1 A conflict of interest is defined as follows: Actions or situations which could lead to an individual’s obligations to the University being influenced or affected by that individual’s considerations of personal gain, or gain to the individual’s family members or friends, whether financially or otherwise.
5.2 These include but are not necessarily limited to:
- Outside activities including paid work which interferes with University duties (staff only)
- Executive and Non-Executive directorships or other interest in a company
- Governorships and trusteeships
- Public appointments
- Consultancy outside the University
- Research projects
- Gifts and hospitality
- Services for personal use from people or companies who do business with the University
- Licensing of intellectual property
- University management decisions
- Shareholdings or other form of equity investment in a company in which the individual is an employee, partner, director, or owner
- Other financial interest in a company in which the individual is an employee, partner, director, or owner.
- Close family or personal links in any of the above
- Relationships with students
- A person is considered as having a financial interest in a company or organisation if s/he is the beneficial owner of more than 5% of the issued capital, is an employee, partner, director, governor or owner.
5.3 If the member of staff believes that a conflict of interest is possible they must declare that interest. If in doubt the member of staff should seek guidance from their line manager or the University Secretary.
5.4 Governors of the University are expected to disclose a conflict of interest outlined in 5.2 and uphold these principles
6. Declarations of interest
6.1 All members of the Board of Governors and UEB will be required to make an annual entry in the Register of Interests, which will be compiled and held by the Office of Compliance Governance and Legal Services (OCGLS). The Register will be available for inspection by members and the relevant sections will be presented to the Governance and Search
Committee and University Executive Board after each annual review. It should be noted that the content of the Register is likely to be covered by the provisions of the General Data Protection Regulations and so subject to disclosure in respect of a Freedom of Information request.
6.2 Members of staff have a duty to make a declaration of interests in accordance with this policy (as defined in point 5 above) and this will be collected as part of the Annual Return that is to be contained within the Performance and Development Review. Any declaration will be reviewed by the line managers and reported to the University
Secretary.
6.3 Members of staff must make a full declaration when asked to do so even where it will be a nil return. Failing to make a declaration when asked to do so will be dealt with under the University’s Staff Disciplinary policy.
7. Staff undertaking external work outside the University
7.1 Individuals are expected to fully commit all of their working time to the University, as specified in their contract of employment. Any work, either paid or unpaid, outside the University is considered a potential conflict of interest (as defined in point 5 above) and must not interfere with a member of staff’s contractual obligations to the University.
7.2 All contracts of employment contain the following clauses which also outlines examples of activities which may be approved under this policy but which must be declared and permission sought. An extract of the contract of employment for Academic Staff, Research Staff and Support (Professional) Staff are set out in Annex A.
Conditions of Service for Academic Staff
Exclusivity of Service
45. External work which is supportive of the professional responsibilities of academic staff is encouraged by UEL.
46. Before entering into an obligation to undertake any external work, including consultancy, academic staff must inform their Dean of School (or nominee); however, by way of exception, this requirement does not apply to the following: -
(a) external examining;
(b) acting as an assessor or moderator;
(c) the production of scholarly works such as books, articles and papers;
(d) any other activity specified in this Handbook as not coming within this
requirement;
47. The Dean of School (or nominee), having consulted with the Provost who is responsible for academic policy, then decide (within 5 working days or whatever other period may be agreed or being reasonable in all the circumstances) if that work will;
(a) interfere with the performance of the academic staff member's professional responsibilities, or
(b) compete or conflict with the interests of UEL, in which case UEL may at its sole discretion require an academic staff member not to undertake the work; such a requirement will not be made unreasonably, will be subject to full consultation with the lecturer and, if made, will be accompanied by full written reasons for it.
48. Where it is intended to use the facilities of UEL in connection with external work, then prior approval is required in accordance with published procedures, which will be included in this Handbook.
Research Staff Conditions of Service
Exclusivity of Service
42. External work which is supportive of professional responsibilities is encouraged by UEL. All external activity of whatever type must be approved in advance by the Dean of School.
43. Approval for the following activities will not normally be withheld provided the Dean of School is satisfied that they can be accommodated within the on-going work of the School without adversely affecting levels of service to users.
(a) external examining;
(b) acting as a moderator or assessor.
44. Prior to entering into any obligation to carry out any other type of external work other than that specified at (a), (b), the prior approval of the Dean of School and of the Deputy Vice-Chancellor responsible for academic policy must be obtained. The Deputy Vice-Chancellor will then decide (within five working days or whatever other period may be agreed as being reasonable in all the circumstances) if that work will:
(a) interfere with the performance of the employee's professional responsibilities, or Research Staff Conditions of Service Part of the UEL Employee Handbook.
(b) compete or conflict with the interests of UEL in which case UEL may at its sole discretion require staff not to undertake the work; such a requirement will not be made unreasonably, will be subject to full consultation with the employee and, if made, will be accompanied by full written reasons for it.
45. Where it is intended to use the facilities of UEL in connection with external work, then prior approval is required in accordance with procedures set out in this Handbook.
46. Any external work as defined above which is approved by the Deputy Vice-Chancellor, shall normally be undertaken through ELCO although other arrangements may from time to time be agreed.
Conditions of Service for Support Staff
Exclusivity
47. All supports staff are expected to devote their whole time service to the work of UEL and shall not engage in any other employment or consultancy without the express agreement of their Dean of School/Director of Service. Such agreement, where it does not conflict with the interests of UEL, shall not be unreasonably withheld.
8. Purchase or supply of goods and services
8.1 Members of staff may, on occasions, be in a position where a conflict of interest arises such as if:
- The supplier is a personal friend
- The supplier is related to the employee
- The employee has a financial interest in the organisation
- The employee may be perceived as having been offered present or future benefit
8.2 If the member of staff believes that a conflict of interest is possible they must declare that interest. If in doubt the member of staff should seek guidance from the University Secretary, the Chief Financial Officer or the Head of Procurement.
8.3 Governors of the University are expected to disclose a conflict of interest outlined in 8.1 and uphold these principles.
9. Relationships
9.1 The University recognises the importance of preserving the integrity of professional relationships between governors, staff and students and between members of staff.
9.2 Staff are expected to conduct themselves in accordance with the Personal Relationships Policy and make disclosures in accordance with that policy.
9.3 Governors of the University would also be expected to disclose such an interest and uphold the principles of the Personal Relationships Policy. For example, the partner of a governor serving on the Board of an organisation with which the University partners or holding equity in a company with which the University contracts, would be deemed to constitute an interest.
9.4 Governors and staff who have such personal relationships must not be involved in the recruitment, selection, appraisal, promotion or other process whereby unfair advantage may be gained over another member of staff or where conflict of interest might exist.
10. Gifts and hospitality
10.1 The offer of a gift, favour or hospitality from whatever source (contractors, suppliers, service providers, students and others) is to be treated with extreme caution to protect:
i. The reputation of the University
ii. Governors
iii. Staff
Even if offered and accepted in good faith, others may misunderstand the intention behind the gift, favour or hospitality which may lead to questions of impropriety and/or conflict of interest.
10.2 The full detail of the requirements for declaring gifts and hospitality are outlined in the Financial Regulations. Governors and staff should also refer to the Anti-Bribery and Corruption Policy (incorporating the Gifts and Hospitality Policy).
10.3 In summary all gifts and offers of hospitality over a value of £30 must be declared to the Head of School/Service. Gifts of over £50 should be declared to the University Secretary. All declarations should be made via the Gifts, Donations and Hospitality Disclosure Form.
10.4 If in any doubt err on the side of caution and if necessary seek advice from their line
manager, the University Secretary or the Chief Financial Officer.
11. How to make declarations of interest
11.1 Declarations of interest should be made online. The place where the declaration can be made is on the Declaration of Interest Form page. Staff who are asked to make a return should update this at least annually or when circumstances change.
11.2 The data will be kept securely in electronic format and strict confidentiality will be maintained.
11.3 The data will be considered by UEB and any conflicts of interest, including paid work outside the University, must be approved by UEB and endorsed by the Dean of School/Service Director.
12. Failure to make declarations
12.1 A culture of transparency, accountability and integrity are core values the University wishes to uphold. The disclosure of interests is intended to balance the protection of governors and staff from exposure to, or allegations of, wrongdoing with the safeguarding of the University from legal claims, reputational damage or financial loss.
12.2 If Governors fail to declare a conflict of interest which subsequently comes to light, then it would be difficult to provide protection from exposure to, or allegations of, wrongdoing with the safeguarding of the University from legal claims, reputational damage or financial loss. Under these circumstances the Governor may be asked to resign or be subjected to the provisions of the Bye-Laws regarding the Deselection of members.
12.3 If staff fail to declare a conflict of interest which subsequently comes to light, the matter will be subject to an internal investigation and, if found to have substance, could lead to action being taken under the University’s Staff Disciplinary policy.
13. Further considerations
13.1 The majority of interests disclosed are not likely to give rise to conflicts between disclosers and the University. Many actual, potential or perceived conflicts of interests will be minor. In most cases, for low significance or low impact conflicts, it is expected that the interest held by both the individual and the University can continue to operate as normal, in the confidence that the interest has been properly managed and understood by all parties.
13.2 The approach adopted to manage the conflict should be documented with evidence that the conflict has been appropriately managed or resolved, as agreed with:
i. For Governors, the University Secretary
ii. For Staff, the individual’s line manager
13.3 The University Secretary will be able to advise in cases of difficulty. In the case of the Board of Governors, the Register of Interests will be reviewed annually by the Governance and Search Committee.
13.4 The Governance and Search Committee will discuss any interests declared which would require proactive management, for example by a member of the Board being excluded from discussion of matters related to the interest declared and agree a way forward.
13.5 At each meeting of the Board and its committee members are invited to declare interests in respect of the business on the agenda so that the members can take a view on the appropriate way of dealing with the conflict of interest.
13.6 ‘Related Party’ and ‘Related Party transactions’ are terms used in financial reporting and accounting to draw attention to the fact that the financial position and profit or loss of an organisation (the University) may have been affected by the existence of related parties and by transactions and outstanding balances with such parties. The majority of staff who are required, or who decide to complete an entry in the University’s Register of Interests are unlikely to be considered a ‘related party’ according to the technical meaning of the terms, e.g., having control, joint control, significant influence or being key management personnel of the reporting entity. There is a higher degree of probability with senior staff and governors than an interest may lead to a Related Party Transaction, because of their seniority within the University.
13.7 The University Secretary will conduct the declaration of interests exercise for Governors and UEB annually and, periodically (at least once a year), make sure staff are aware of this policy and of the need to make a declaration.