A copy of this policy is available
to download as a pdf here.
1.1 The University avoids actual
and potential conflicts of interests where possible. We act
honestly, ethically and transparently. We declare both actual and
perceived conflicts of interest and take appropriate action to
manage the conflict.
1.2 Senior staff, particularly
those with responsibility for budgets or contracts, must take
proper care that any conflict of interest, actual or perceived,
does not arise from their position with the University or
membership of or connection with other bodies and individuals
outside the University.
1.3 Each year the University
requires senior members of staff to complete a declaration of
interests form to identify any potential conflicts of interest.
1.4 All staff, regardless or
position or seniority, are under a duty to disclose conflicts of
interest, actual or possible, to ensure the University acts in a
manner which is honest, ethical and transparent.
A conflict of interest is a
A conflict of interest can
therefore be perceived or actual. Its existence does not
necessarily arise due to unethical or unlawful bahevaiour, it may
just be a coming together of circumstances.
The important matter is not how the
conflict arose, but what impact this conflict may have or be
perceived to have.
It is possible to prevent a
conflict of interest, either perceived or actual, by being
transparent about the conflict. By appropriately managing the
conflict, you may still be able to perform a function or task where
a conflict exists. However, this decision will be made by the Vice
It is essential
that actual or potential conflicts of interest are brought to the
attention of the Secretary to the Board as keeper of the register
of interests so that a determination can be made as to what action
should be taken to manage the conflict or if appropriate, avoid the
This policy applies to all
University staff and governors. In relation to staff, the
Regulations dated 6th February 1989 state:
"18.1 Any member of staff
of the University who has a pecuniary, family or other personal
interest, direct or indirect, in any contract, or proposed
contract, entered into on behalf of the Corporation shall declare
this interest to the Clerk to the Board of Governors".
This duty also applies to any
member of the Board of Governors as the Financial Regulations dated
6th February 1989 state:
"18.2 In like manner, any
member of the Board of Governors who has a pecuniary, family or
other personal interest, direct or indirect, in any contract, or
proposed contract, entered into on behalf of the Corporation shall
declare this interest to the Clerk to the Board of Governors who
shall maintain a register for the purpose".
It is important that the University
is able to conduct its business transparently, ethically and within
the law. Due to the wide nature of University activities, there may
be situations where staff place themselves in a difficult position
where an outside interest may conflict, or appear to conflict with
their duties disclose is the norm and in the event of any doubt it
is better to disclose rather than not.
For the purposes of this policy, a
"relative" means a family member of the individual concerned:
If you think you may have a
conflict, you should ask yourself whether members of the public,
knowing the facts of the situation, could reasonably conclude the
interest involved might have influenced their decision. If
in doubt, disclose the conflict.
If you think or know you might have
a conflict of interest you must report this to your line manager
and the Secretary to the Board using the conflict
of interest form. You can return your
form to email@example.com or
by post to Corporate Strategy & Governance Unit, MA216, City
The Secretary to the Board will, if
necessary, discuss the form with you and taking account of the
nature of the conflict and your role in it, make an assessment of
the risk the conflict actually presents and advise you
Note, you must not
do any work, enter into any transaction or do anything else that
may be affected by the conflict of interest unless suitable
mitigations have been put in place and have been approved by the
Secretary to the Board.
Again, staff should ask themselves
whether members of the public, knowing the facts of the situation,
could reasonably conclude the interest involved might have
influenced their decision. If you feel your colleague has a
conflict of interest you should raise this with your line manager
who will decide whether to approach the Secretary to the Board.
Action can be taken to manage a
conflict. This matter will be considered by the Secretary to the
Board who could decide the following course of action:
This list is non-exhaustive and it
may be possible to combine the above actions to appropriately
manage a conflict. However, if in doubt, always disclose the
Should you fail to disclose a
conflict and go ahead and act, you may be subject to disciplinary
proceedings. It is difficult to prescribe every situation where a
conflict may arise and each matter will be considered on its own
merit and individual circumstances.
Staff must ensure they take care
not to solicit or recommend any person for employment by the
University or for admission to it, other than through the proper
procedures and must disclose if a candidate is related to them when
Approved by Board of Governors on
5th July 2012.
University of Wolverhampton, Wulfruna Street, Wolverhampton, WV1 1LY
Course enquiries: 0800 953 3222, General enquiries: 01902 321000 | Email: firstname.lastname@example.org
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