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Conflicts of Interests Policy

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College Policy on Conflicts of Interest

1. Introduction

1.1 Goldsmiths is a creative, tightly knit campus which encourages all staff across   both academic and professional services areas, to pursue excellence in their work.  This includes collaborating with local, national and international partners. 

1.2 It is inevitable in such a busy and vibrant community, that conflicts of interest will arise, especially where an individual is in a niche role, a senior position or has a commitment or role in an outside organisation. 

1.3 It is essential that Goldsmiths is able to demonstrate integrity in all of its endeavours and the intention of the policy is to provide members of the college with a supportive and transparent approach. A conflict of interest is not, in itself, an indication of any wrong doing on behalf of a staff member.  

2. Scope 

2.1 This policy applies to all Goldsmiths staff and Council and Committee members and to students when acting in an official College capacity. The policy describes the possible personal, social, financial and ethical considerations, which may result in an actual or perceived conflict of interest and how they may be managed.  

3. Conflict of Interest

3.1 In the absence of a legal definition of a conflict of interest, an interest should broadly be considered as a connection which may interfere with an individual’s ability to discharge their duties with propriety.

3.2 According to the Committee on Standards in Public Life ‘Holders of public office must avoid placing themselves under any obligation to people or organisations that might inappropriately try to influence them in their work. They should not act or take decisions in order to gain financial or other material benefits for themselves, their family, or their friends. They must declare and resolve any interests and relationships’ 

3.3 Council, Committee members and senior members of staff must declare their interest on a published Register of Interests

4. Register of Interests

4.1 As a publicly funded body with charitable status, Goldsmiths is required to maintain a register of interests to demonstrate proper conduct of the Council, Governing Committees and senior staff members which is publically available. The register is annually reviewed by Executive and Governance Services, who will make contact with departments and Council to seek declarations and confirm any current or potential conflicts of interests. 

4.2 Nonetheless, disclosures may be made at any time and should be made, where possible, before a member of the College has engaged in any activity. These should be declared in writing to the Registrar and Secretary.

5. Terms of appointments

5.1 Goldsmiths will ensure that members of the college are aware, under the terms of their appointment that they will act responsibly. 

5.2 To ensure there is no undue pressure in the decision making process and in the conduct of College business, where a member of the College has an interest in a matter under Council or committee consideration, that member must declare it and abstain from the discussion and any vote.

5.3 Where, due to a number of Council or Committee members being affected by a conflict of interests and being unable to make decisions, it may be appropriate that the matter is referred on to a separate committee.  

6. General Conflicts of Interest

6.1 Where there may be an actual or perceived personal benefit as a result of knowledge, influence or relationships, the member of the College should be followed as outlined in para 7. These conflicts may occur because of a set of unforeseen circumstances which may affect staff members. 

6.2 Examples of when a conflict of interest can arise

• Financial

Conflicts of interest may occur when outside financial interests compromise, or have the appearance of compromising, the professional judgement of an individual.  

• Personal

A personal conflict of interest is a situation where a person’s private interests such as outside relationships or personal financial assets interfere or may be perceived to interfere with their performance of their duties.

• Political 

Public officials, as stewards of trust, are required to put the public interest before their own.  Impropriety occurs when an official puts their personal interests ahead of the public interests.

7. Managing a Conflict of Interest for staff members

7.1 Staff members who identify a perceived or actual conflict of interest should raise this with their Head of Department. Where this is no possible, staff members should inform Governance, where a full disclosure may be recorded, but not published. These records may be routinely inspected by third parties, for example auditors.   

7.2 Where a staff member believes the conflict of interest no longer exists they are advised to put this in writing requesting that their disclosure is closed.

7.3 Where circumstances require that a conflict of interest is managed, the approach and mitigation should be formally recorded. Any particularly difficult matters or where agreement about the mitigating approach cannot be reached should be referred to the Registrar and Secretary and the relevant School Pro –Warden, who will have the final decision.

7.4 As part of their contract of employment all staff are obliged to notify the college about any prospective outside work or consultancy and seek Goldsmiths permission, which it may refuse.

8. Gifts and Hospitality

8.1 Goldsmiths rules on accepting gifts, rewards and hospitality are detailed in the Policy on Corporate Gifts and Hospitality.

9. Financial Conflicts of Interest

9.1 Financial conflicts of interest are detailed further in Section 8 of the Financial Regulations. 

10. Personal Conflicts of Interest

10.1Goldsmiths values professional relationships based on trust and confidence, where there is a requirement to provide academic teaching and support, pastoral support or administrative and technical support, consistent with the staff members role and Goldsmiths Regulations. 

10.2 Goldsmiths recognises that good professional relationships across the college are an important part of both the student and staff experience, promoting good working and academic relationships.   

10.3 There may be circumstances where due to a personal relationship a staff members should abstain from making certain decisions and undertaking certain duties in order to avoid allegations of unfair treatment and bias, which could bring complaints against the staff member and the College. A personal relationship may be defined as:

• A family relationship

• A business / commercial / financial relationship

• A sexual / romantic relationship

10.4 This is even more important where there may be a difference in power between the parties or a perceived or actual vulnerability of one of the parties.  Staff members should not lay themselves open to allegations and where they identify a conflict of interest, this should be raised with the Head of department or Pro-Warden where the staff member is a Head of Department. 

Goldsmiths has a separate policy on Personal Relationships which can be found [here].

11. Further information and support

11.1 Staff members who are uncertain about whether they should take action regarding a personal relationship are invited to speak in confidence to the Director of HR. Staff and students may discuss concerns relating to conduct in confidence with the Colleges counselling service.

11.2 Both HEFCE and CUC have published guidance for publicly funded bodies and this policy is written in keeping with their principles.