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Declaring conflicts of interests and gifts and hospitality

Declaring Conflicts of Interest, Gifts and Hospitality

Guidance for staff on how to declare an actual or potential conflict of interest and gifts/hospitality relating to their role.

Staff of the University are expected to act in accordance with the University’s values of being Inclusive, Collaborative and Impactful and the principles established by the Committee on Standards in Public Life (the Nolan Committee): selflessness, integrity, objectivity, accountability, openness, honesty and leadership. Staff must not use their authority or office for personal gain and must always seek to uphold and enhance the standing of the University.

Declaring conflicts of interest

Under the University's Financial Regulations, all staff are expected to declare any conflicts of interest which may affect the conduct of the University’s business and to act in accordance with the directions received in managing the conflict of interest. You should declare any actual or potential conflicts of interest as soon as you become aware of them using the form below:

When considering whether there is an actual or potential conflict of interest, you should include your 'connected persons' (e.g. your spouse, civil partner, long-term partner, close relatives, a business which you or your connected persons control or have a substantial interest in) as well as yourself. For the purposes of the declaration, an interest is defined as:

  • Any significant shareholding or material interest in an organisation which may supply or trade with the University of Greenwich and its subsidiaries.  Relationships that might be relevant include consultancy, employment, directorships, partnerships, shareholdings, memberships or the trusteeships of charities;
  • Any matter which may reasonably be deemed by others to encroach on impartiality;
  • Any person, financial or other beneficial interest which you or your 'connected persons' may have in any financial arrangements with the University of Greenwich.

Further guidance on what should be declared is provided on the form

Examples of conflicts of interest include (but are not limited to):

  • Being connected to a supplier (e.g. via a financial interest) where you will be involved in the procurement decision or in managing the supplier;
  • Setting up a company to exploit University IP for your own benefit without authorisation;
  • Accepting a part-time job or a visiting professorship at another organisation where this will conflict with your Greenwich role;
  • Using University resources to support unauthorised consultancy for your own benefit;
  • Having an interest in a business that would compete against the University for similar work;
  • Having an interest in a business that benefits from an activity run by the University;
  • Entering into a partnership with another organisation with which you have a pre-existing interest or relationship;
  • Being a signatory to a University contract where you (or person(s) connected with you) also have an interest in the activities of the other party.

Senior staff and certain categories of staff are also required by the University to complete an annual register of interests declaration - however, that does not remove the need to declare actual or potential conflicts of interest as they arise.

The Financial Regulations specify who is authorised to determine how conflicts of interest should be managed.  Staff must act in accordance with the directions which they receive for managing the conflict.

Personal relationships: The University has a separate procedure for declaring personal relationships which may affect a staff  member's employment, including personal relationships between staff and students, between staff, between staff and third parties, between a line manager and their direct report, between a job applicant and a staff member, and between a job applicant and a student.  The Personal Relationships at Work Policy specifies what must be declared and the process for declaring personal relationships.

Declaring gifts and hospitality

Staff may not accept any gifts, rewards or hospitality (or have them given to members of their families) from any organisation or individual with whom they have contact in the course of their work that would cause them to reach a position whereby they might be, or might be deemed by others to have been, influenced in making a business decision as a consequence of accepting such hospitality.

Members of staff may accept normal courtesy hospitality (such as business lunches or attendance in an official capacity at a public function) and low-value promotional gifts. Care must always be taken to ensure that whenever such hospitality or gifts are accepted, no obligation to the person or organisation offering the hospitality or gifts is created.

The following types of hospitality/gifts must be declared by all staff:

  • Attendance as a non-paying guest of a commercial organisation or individual at a non-work related cultural or sporting event;
  • The acceptance of any gift valued in excess of £50, including multiple individual gifts from the same source whose total value is more than £50.

Staff are required to obtain approval from their line manager before accepting gifts in these categories.

Gifts and hospitality should be declared using the form below:

Senior staff and certain categories of staff are also required to complete an annual declaration of gifts and hospitality - however, that does not remove the need to declare gifts and hospitality as they arise.

For further information on the University’s requirements related to declaring conflicts of interests and gifts/hospitality, see the University’s Financial Regulations and the Anti-Bribery Policy. For questions relating to matters covered by this webpage, contact the University Secretary.