Conflicts of Interest, Gifts and Hospitality

   
   

As a custodian of public funds the University must maintain high standards of propriety and probity. Members of staff may on occasion be offered gifts or hospitality simply as a mark of courtesy or gratitude. Such offers can place staff in a difficult position, since to refuse may cause offence but to accept may, in certain circumstances, be open to misinterpretation. These guidelines have been drawn up to avoid misunderstanding and to help staff deal with these difficult situations. University Executive Board has approved them and the Audit Committee is aware of their existence.  The University expects all of its staff and students to follow the ethical behaviours set out in the Nolan Principles.  Those are: selflessness, integrity, objectivity, accountability, openess, honesty and leadership.  These principles underlie the Univeristy's Ethical Framework and are incoporated into this policy. 

Guiding Principles

These are:

  • The conduct of staff must not create suspicion of any conflict between their duties as employees of the University and their private interests.
  • The actions (or inaction) of members of staff on behalf of the University must not create an impression to any third parties that they may have been influenced by a benefit to show favour or disfavour to any person or organisation.

Guidance

Gifts

Gifts from suppliers or potential suppliers of goods and services to the University (other than items such as diaries, calendars etc) should be declined (refer to University Purchasing Policy for details).

Otherwise, gifts of an estimated value of up to £140 may be accepted at the discretion of the recipients. Any other gifts should be politely refused. However, where to refuse might reasonably be interpreted as giving offence or causing embarrassment, the gift should be accepted on behalf of the University, provided the recipient is satisfied that it is not being offered in return for any favour. Receipt of gifts in the latter category should be reported as soon as practicable to the Registrar who shall enter them on a register held for this purpose. The Registrar shall decide whether the recipient may retain the gift, whether the University should retain it, whether it should be disposed of e.g. to charity or, exceptionally, returned to the donor with an explanatory letter.

Hospitality

Hospitality such as meals or refreshments offered in the normal course of business may be accepted. As a general rule of thumb the frequency and scale of hospitality should not be significantly greater than the University would be likely to provide in return. Hospitality that might be regarded by a reasonable person as excessive in the circumstances or as a possible inducement should be politely declined. In such cases staff may find it helpful to refer to these guidelines.

In particular, the following should be avoided:

  • hospitality offered in lieu of bona fide fees or expenses;
  • inducements which might be interpreted as being intended to create a contractual relationship between the University and a supplier of goods or services;
  • offers of hospitality, including travel or accommodation, except as part of an overall contract or memorandum of understanding;
  • regular or frequent acceptance of corporate hospitality, particularly from the same source.

In cases of doubt, colleagues should consult their Head of School/Department who may, if necessary, consult the Registrar, whose decision shall be final.

<start_c>

Other possible conflicts of interest

If a member of staff has any third party pecuniary or non-pecuniary interests which may give rise to conflicts of interest in the carrying out of their University duties, they should report them to their Head of School/Department and to the Registrar or Research and Graduate Services Director. The University maintains two Register of Interests, one maintained by the Registrar in respect of members of Council (to which the Registrar, the Internal Audit Service and HEFCE have access) and another for senior staff maintained by the Research and Graduate Services Director (to which the Research and Graduate Services Director and the Internal Audit Service have access). Interests are entered on the registers and kept by the Registrar and Research and Graduate Services Director. The registers may, at the discretion of the Registrar, be made available for inspection upon request by any person or body. For the avoidance of doubt, membership of the staff of the University shall not be regarded as a pecuniary interest for the purpose of discussing or deciding upon remuneration and conditions of service for staff in general.

In deciding whether to register an interest, staff should ask themselves whether members of the public in possession of the facts of the situation could reasonably conclude that the interest might influence the member of staff to act other than in accordance with the Guiding Principles detailed above. If so, the interest should be registered and the member of staff shall take no part in consideration of any matters associated with that interest.

Senior staff and members of Council are required to complete an annual declaration of interests form.

Registrar
November 1997
Updated August 2014

Last edited Jul 13, 2016