Declaration of interests policy

1. Rationale

1.1 This Policy sets out the requirements by which 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 West 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 Policy on Staff - Student Relationships. 

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.

2. Scope of the policy

2.1 This Policy applies to all 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 Regulations for the Board of Governors. The Register of Interests of all members of the Board, including those of staff members are available on the Board of Governors page. This register also includes the interests of VCE members.

3. Related policies

3.1 Staff should also ensure that they abide by the following:

• Code of Ethics
• Financial Regulations
• Staff/Student Relationships Policy
• Anti-Bribery Policy
• Intellectual Property Policy

4. Summary principles

4.1 This policy is based on the following principles:

• 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 VCE 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
• Consultancy
• Research projects
• Gifts and hospitality
• Services for personal use from people or companies who do business with the University
• Executive and non-executive directorships or other interest in a company¹
• Licensing of intellectual property
• University management decisions
• Relationships with students

^{1. 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.}

6. Declarations of interest

6.1 All employees have a duty to make a declaration of interests in accordance with this Policy through the on-line form for consideration by the appropriate VCE member and to notify their line managers of their interests. 

6.2 Employees must make a full declaration when asked to do so even where it will be a nil return. Failing to make a declaration will be dealt with under the University’s Disciplinary policy.

7. 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. Appendix 1 outlines examples of activities which may be approved under this policy but which must be declared and permission sought.

7.2 All contracts of employment contain the following clauses (paragraph 17):

7.3 You are required to devote your whole time and attention to your duties during your working hours and to act in the best interests of the University at all times. 

7.4 You must notify your line manager of any employment or engagement which you intend to undertake whilst in the employment of the University, including any employment or engagement which is ongoing or commenced before your employment with the University. 

7.5 You must not, without the written consent of the University, undertake any employment or engagement, which might interfere with the performance of your duties or conflict with the interests of the University. You must complete an annual Declaration of Interests form.

7.6 You are required to notify your head of school/service of any employment, engagement, or consultancy etc. which you intend to undertake whilst in the employment of the University (including any such employment or engagement which commenced before your employment under this contract). Your declaration will be considered by the appropriate member of the Vice Chancellor’s Executive (VCE). You will then be notified of the University’s consent or objection to you undertaking such additional activities or employment. Please note that such consent may only be given by VCE members. Such authorisation must be received before any external work commences.

7.7 Employees are reminded that to undertake paid work in addition to their contract with the University without written permission is a disciplinary offence and will be dealt with in line under the University’s Disciplinary Policy. For this purpose running your own company is included in the definition of paid work.

7.8 Even where permission is given you must not use University facilities to undertake any work as set out in the Financial Regulations.

8. Purchase or supply of goods and services

8.1 Employees 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 employee believes that a conflict of interest is possible they must declare that interest. If in doubt the employee should seek guidance from the University Secretary and Registrar, the Chief Financial Officer or the Head of Procurement.

9. Relationships

9.1 The University recognises the importance of preserving the integrity of professional relationships between staff and students and between members of staff.

9.2 Where a personal relationship exists between members of staff who also have direct or indirect line management or a supervisory relationship, the existence of the personal relationship must be disclosed to the Head of School/Service. In the context of this document, a personal relationship is defined as a family relationship; a business/commercial/financial relationship; or a sexual/romantic relationship, however brief.

9.3 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. 

9.4 In line with the Policy on Staff/Student Relationships, personal relationships with students are strongly discouraged. However, in line with the policy, if such a relationship is already in existence or does develop, this must be declared in line with the above Policy.

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) Staff personally

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. Staff should also refer to the Anti-Bribery 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 and Registrar and Chief Compliance Officer. 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 and Registrar or the Chief Financial Officer.

11. How to make declarations of interest

11.1 Declarations of interest should be made online. This site for completion can be found on the Declaration of Interest Form page. All staff are expected to make a return, which should be updated as and when circumstances change, and at least annually thereafter.

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 VCE and any conflicts of interest, including paid work outside the University, must be approved by VCE and endorsed by the Head of School/Service.

12. Failure to make declarations

12.1 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 disciplinary action including in serious cases dismissal.