Managing conflicts of interest for secondees into EPSRC Leadership Team

1. Purpose

To observe the high standards of integrity expected by the public and Parliament, the proper conduct of public business requires EPSRC Leadership Team (ELT) members to avoid situations in which their duties and other interests conflict or where members of the public might reasonably think that an interest could influence judgement.

This document sets out the principles for managing conflicts arising for those members of ELT seconded into EPSRC on either a full time or part time basis.

2. Background

All personal and business interests of a seconded individual, which might conceivably conflict with his or her responsibilities as a member of ELT, must be declared and registered and be available to public scrutiny.

The issue of declaring and managing potential conflicts is covered in the Code of Conduct for EPSRC employees (PDF), which states that:

"Employees must declare to their manager any financial or non-financial interests that a reasonable person might conclude were in conflict with the interests of the Council. Any such declaration shall be kept on a Register of Interests held locally"

"Employees must declare to their manager any financial or non-financial interests that a reasonable person might conclude were in conflict with the interests of the Council. Any such declaration shall be kept on a Register of Interests held locally"

In the context of EPSRC business, a conflict of interest can be defined, for example, in terms of close links with, or an interest in, a particular institution or business from which a grant or other funding application or initiative is being considered, or a private or commercial interest in such an application. In the case of seconded members of EPSRC, this is most likely going to involve the secondee's host employer or key business partner.

3. Managing the conflict

3.1 Perceptions

From the view of external perceptions, EPSRC should not only manage conflicts well, but should also be seen to be doing so. This means acting conservatively, i.e. where there is any doubt, seconded members of EPSRC should not be involved in decisions, or participate in any discussions that might lead to decisions, about matters in which they might be perceived to have such an interest. The minutes of any such meetings should record any conflict of interest, any withdrawals from the meeting and the reason for the conflicted members return.

3.2 Actions

  • All prospective decisions the secondee is required to make that might be considered a conflict will be referred in the first instance and at the earliest possible opportunity to the Chief Operating Officer (Andrew Lewis) who will decide in consultation with EPSRC, as appropriate, how best the conflict should be managed. This might include reference to an oversight group (see below).
  • An oversight group will be established to resolve issues of potential conflict where the remediation is not obvious in advance. The membership of this group will be determined depending on the conflict, but should include at least two people of which at least one should be a more senior person (e.g. Chair of Council if conflict is with CEO, or CEO if conflict is with Deputy CEO etc).
  • Secondees will absent themselves from:
    • Council and Executive Leadership Team (EPSRC) (and where appropriate RCUK/RUK) discussions that relate to funding or funding proposals involving their host employer.
    • Any appointment processes where shortlisted candidates included employees from their host employer.
    • Discussions related to an EPSRC negotiating position with the host employer, including any related papers or minutes of relevant discussions.
  • Secondees will not be an applicant or co-applicant on any funding proposal submitted to EPSRC.
  • Where discussions concern the host employers wider sector, and where other members of the sector might perceive themselves to be adversely influenced by the secondees affiliation with the host employer, EPSRC will identify and manage conflicts appropriately and on a case-by-case basis. Where a conflict is identified, the Chief Operating Officer will decide who should be the EPSRC 'senior responsible officer'.
  • If staff are in doubt as to how to manage a possible conflict, they should first consult the Chief Operating Officer.
  • A log will be maintained of instances where a potential conflict for secondees has been raised, and action either taken or not taken. This will be available to EPSRC Council and would form the basis for example of any media queries or Freedom of Information requests.