Introduction
UKRI is a publicly funded organisation and is accountable to government and the public for its actions. It must conduct its business in a way that is transparent and guards against potential conflicts of interest influencing the outcome of decisions.
UKRI defines a conflict of interest as a situation where an individual’s ability to exercise judgement or act in one role is, could be, or is seen to be impaired or otherwise influenced by their involvement in another role or relationship. Even a perception of competing interests, impaired judgement or undue influence may be damaging to UKRI’s reputation.
The existence of an actual, perceived or potential conflict of interest does not imply wrongdoing or that the assessor is not well placed to make an impartial assessment. However, as an assessor, it is vital that you are seen to be impartial at all stages of the decision-making process.
If you have any private, personal or commercial interests which might cause such a conflict of interest, you must recognise it, disclose it appropriately, and either eliminate it or manage it properly.
Everybody involved in UKRI decision-making and funding processes must comply with UKRI declaration of interest policy. UKRI will support all individuals to ensure compliance of the policy.
Declaring conflict of interest information
Applicants may declare potential conflicts of interest in their application, related to individuals or organisations. UKRI will avoid asking these potentially conflicted individuals or organisations to assess that application when feasible and if the request meets UKRI definitions of a conflict as defined in the UKRI declaration of interest policy.
Reporting, recording and managing potential conflicts effectively protects assessors (reviewers and panellists) and helps ensuring a transparent decision-making process.
UKRI acknowledges that individuals working in the same research and innovation field may know each other. This does not prevent them from assessing an application. However, as assessors, they must declare any interest which they feel would prevent them giving an unbiased assessment.
Once an assessor declares interests, UKRI evaluates them and decides if they are actual, perceived or no conflict. If the assessor’s knowledge of or relationship with the application or applicants is such that they feel it would be difficult to be impartial when commenting on the application, we ask them to decline the invitation to be part of the assessment by selecting ‘conflict of interest’ as the reason why.
For reviewers
Some UKRI review forms contain a confidential section on ‘declaration of interests’, where you need to disclose relevant information (including a ‘N/A’ (not applicable) if that is the case). If in doubt, we encourage you to discuss your circumstances with the UKRI office administrator managing the assessment process.
If you are unsure how to proceed, check with the UKRI member of staff who approached you to carry out the review.
For panellists
If you are part of a collective decision-making process (such as a panel, a committee or an interview panel) and a conflict of interest has been identified, this can impact your role in the process. It might mean that you have limited access to the application materials related to the conflict. You may be asked to leave the room when the application is being discussed.
Examples of conflicts of interest for assessors
The list below shows examples of conflicts of interest, including but not limited to review and panel stages. The list is not exhaustive. You must declare any actual or perceived conflict of interest, reflecting on the perception of both yourself and others.
Personal conflict
There is a personal conflict if:
- you are named on the application
- you have assisted the applicants in preparing the application
- you are named as a project partner, subcontractor, visiting researcher or have any type of relationship with the application
- you have written a letter of support for the application
- you have agreed to be a member of a committee or board connected with the proposed project, for example an advisory group, or steering committee or board
- you are in close regular collaboration with any individuals named in the application, including investigators, research staff, collaborators, subcontractors and project partners, to an extent where you feel uncomfortable being involved in the discussion or you feel unable to give an unbiased opinion
- you have a personal, financial or professional relationship with any individuals named in the application
- you have been any of the applicants’ PhD supervisor, line manager or group leader, or they have been your PhD supervisor, line manager or group leader in the last three years
- you stand to gain a financial or professional advantage from a particular outcome for an application you are asked to review
Organisational conflicts
There is an organisational conflict if:
- you are a current, Emeritus, secondment or visiting member at the same or proposed organisation as any individuals named on the application (this includes holding a position on the governance body or an honorary position within the applicant’s current or proposed organisation)
- you belong to an organisation that is a project partner or subcontractor, or you are a visiting researcher from or to the organisation
- you have any type of recognised significant organisational collaboration with the application which would mean that your participation in the assessment would be seen as a conflict
- you are personally paid more than £5,000 per year from the applicant’s current or proposed organisation
- for fellowships only: you are at an organisation chosen by the candidate to be the hosting organisation for their fellowship
Commercial or financial conflicts
There is a commercial or financial conflict if:
- you have any commercial, financial or pecuniary interest, for example where you are a member of an organisation that may benefit financially, directly or indirectly, from any decision made
- you have stocks or shares in a company named in an application
Managing conflicts in our decision-making process
UKRI responsibilities
UKRI staff will make all reasonable efforts to identify and record any real or perceived conflict of interest that involve anyone related to our assessment and funding processes.
UKRI staff will not invite any assessor with a known conflict of interest to be part of our assessment process for that application.
Depending on the conflict of interest and business needs, UKRI staff will consider introducing measures to manage and minimise the risk potentially raised by the conflict.
UKRI will give assessors the opportunity to self-identify any potential conflict of interest that might not have been apparent in previous stages of the process. We expect the assessor to identify these to UKRI staff, who will introduce reasonable measures to minimise the risk from this conflict.
UKRI will not share application assessment information with assessors who are not involved in the assessment of the application. For example, we will not share reviewer comments with conflicted panellists.
UKRI will manage any conflict that becomes apparent at different stages of the funding process to safeguard the integrity of the assessment.
Reviewer responsibilities
When you are invited to review an application for UKRI, you will receive a summary of the application and the name(s) of the applicant(s). If you know of any conflict of interest you must declare it at this stage and select ‘conflict of interest’ as a reason when declining the invitation.
If you are unsure whether you have a conflict of interest, you should contact UKRI to discuss your concerns before deciding to accept or decline a review invitation.
If you accept an invitation to review and then identify a conflict of interest, you must let UKRI know as soon as possible.
If a conflict becomes apparent, either to you or to UKRI, after the submission of a review, we will classify your review as ‘unusable’ and will not use it in the decision-making process.
Panellist responsibilities
If you have a known conflict of interest, you will not be able to access application assessment information (for example, reviewer comments for those applications) to protect the integrity of the assessment process.
If you believe that UKRI has missed a potential conflict of interest, you must communicate this to UKRI staff as soon as possible.
Depending on the nature of the conflict, we may need to alter your role in the assessment process. This can include your withdrawal from the panel meeting for the discussion of the application.
For any other reason, you may voluntarily choose to withdraw from the discussion of an application at any time. The secretary to the panel should record in the minutes the point at which an individual ceases to take part in the discussion and leaves the meeting.