Good governance in public sector organisations recognises the need to have arrangements in place that prevent, counter and deal with potential conflicts of interest.
It is important in this context that UKRI guards 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 situation in which 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.
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 or some other person or entity, or both
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 UKRI and it’s 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 or individual
- in receipt of secondary income from a business or 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 in a commissioning decision (as those categories are described above) for example:
- spouse or partner
- close relative (for example, parent, grandparent, child, grandchild or sibling)
- close friend
- business partner
- a financial relationship (for example, a pension) with a business or 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 or individual
- a volunteer for business or individual
- 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 non-financial professional interest or a non-financial personal interest in a commissioning decision (as those categories are described above), for example, a:
- spouse or partner
- close relative (for example, a 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 (such as 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
- 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).
Find out more about conflicts of interest
UKRI declarations of interest policy and guidance.
Our declaration of interests policy requires our senior leaders and those involved in decision making 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.
Declarations of interests are updated annually or when an individual requires an amendment to be made to their details.
View the UKRI Board and Executive Committee declaration of interest registers.
Last updated: 11 September 2023