• Section 1 - Purpose and Scope
• Purpose
• Scope
• Section 2 - Process and Key Controls
• Section 3 - Principles and Key Requirements
• Identifying a Conflict of Interest
• Disclosing a Conflict of Interest
• Managing a Conflict of Interest
• Disclosure and Management of Interests
• Privacy
• Section 4 - Roles, Responsibilities and Accountabilities
• University Staff
• Supervisors
• Integrity Unit
• Section 5 - Monitoring, Review and Assurance
• Section 6 - Recording and Reporting
• Disclosure and Management of Interest Register
• Section 7 - Appendix
• Definitions and Terms

Section 1 - Purpose and Scope

Purpose

(1) This Procedure supports The University of Queensland’s (UQ or the University) Conflict of Interest Policy and outlines the processes for identifying, disclosing and managing conflicts of interest at UQ.

Scope

(2) This Procedure applies to all University staff (including contractors).

(3) Where transient conflicts occur through service on panels, such as appointment or procurement panels, the disclosure of the conflict should occur either verbally in the meeting or on the appropriate form, see UQ Recruitment, Selection and Appointment Policy or UQ’s Procurement Policy respectively.

(4) Sources of research funding need to be disclosed so that research outputs can be objectively assessed by users. All sources of financial and in-kind support for a research output must be disclosed in the acknowledgements of the research output in accordance with the UQ Authorship Procedure. 

(5) Where a conflict relates to the commercialisation of research, this Procedure must be read in conjunction with the Disclosure of Interests relating to Commercialisation Procedure.

(6) This Procedure does not apply to Senate Members. The Conflict of Interest and Disclosure Procedure for Members of Senate provides the process for Senate Members to disclose and manage a conflict of interest.

Section 2 - Process and Key Controls

(7) All staff must assess their private and personal interests and identify whether those interests may conflict with their official UQ duties and responsibilities.

(8) All staff are required to disclose their conflicts of interest and suggest management plans for approval using the online disclosure tool.

(9) Local Managers review conflict of interest management plans to ensure the efficient and effective management of the conflict of interest.

(10) Conflict of interest management plans are approved by the relevant approval authority.

1. Once a staff member discloses a conflict of interest and suggests a management plan using the online disclosure tool, their Local Manager will review the management plan and either request further information or changes to be made by the staff member, or recommend the management plan be approved or not by the Senior Leader.
2. Senior Leaders will review the management plan and either request further information or that changes are made by the staff member before they approve the plan or not.

Section 3 - Principles and Key Requirements

Identifying a Conflict of Interest

(11) A conflict of interest may include circumstances involving a staff member’s:

1. competing external interest or obligation;
2. personal financial interest;
3. personal relationships; or
4. receipt of personal benefits.

(12) When considering whether a conflict of interest exists, staff should consider:

1. whether the interest, relationship or obligation is consistent with community values, standards and behaviours, and the principles outlined in the University’s Staff Code of Conduct Policy;
2. how the interest, relationship or obligation might be viewed or perceived by other people; and
3. whether the interest, relationship or obligation may compromise their ability to exercise impartial leadership, management or judgment.

(13) Staff should also alert supervisors to conflicts of interest held by other staff where they have a reasonable belief the conflict of interest has not previously been disclosed.

Disclosing a Conflict of Interest

(14) When a staff member identifies a conflict of interest, they must disclose the conflict using the online disclosure tool and submit it to their Supervisor.

(15) Where a conflict of interest arises during a meeting, the staff member must verbally disclose it and have it formally noted (e.g. in minutes of the meeting).

(16) Where a Supervisor becomes aware of a potential conflict of interest that has not been disclosed by a member of their staff, they should discuss the matter with the staff member and ensure the conflict is disclosed and managed appropriately using the online disclosure tool.

(17) Where circumstances affecting an existing or previously disclosed conflict of interest change, the staff member must amend the disclosure and submit a revised disclosure and management plan using the online disclosure tool for approval.

Managing a Conflict of Interest

(18) When a staff member has identified and disclosed a conflict of interest, they must develop a plan with their Supervisor to resolve or manage the conflict. A conflict of interest management plan includes:

1. the nature of the staff member’s private interest;
2. the interests of the University with which the staff member’s private interest conflicts;
3. the likelihood of the interests conflicting;
4. an outline of risk management strategies to be implemented; and
5. the recommended measures to be taken.

(19) Once a conflict of interest management plan has been developed, it must be approved by the relevant Senior Leader using the online disclosure tool.

(20) The management plan should be reviewed annually or when circumstances change involving the staff member’s conflict. The staff member and their supervisor are responsible for ensuring that the management plan remains appropriate.

Disclosure and Management of Interests

(21) The Conflict of Interest Policy and associated procedures is part of a framework for the governance and management of public and private interests across a number of related areas of activity.

(22) The disclosure and management of these interests requires relevant staff to complete the following:

1. Conflict of Interest Disclosure Tool
2. Secondary Employment Register
3. Sensitive Research Register
4. Foreign Influence and Interference Register.

(23) To complete the Foreign Influence and Interference Register, staff are required to enter data into the Individual Activity Profile that relates to supervision of students at foreign institutions and the holding of honorary/adjunct appointments at foreign institutions.

Privacy

(24) Any personal information collected, stored, used or disclosed under this Procedure must be handled according to the University's Privacy Management Policy.

Section 4 - Roles, Responsibilities and Accountabilities

(25) Effective conflict of interest management at the University depends on the collaborative efforts of staff members and their Supervisors, in consultation with other relevant parties as outlined below.

University Staff

(26) Staff are responsible for identifying whether a private or personal interest conflicts with their official University duties and responsibilities.

(27) Staff must complete mandatory training, undertake regular self-assessment of their private and personal interests and disclose and manage any relevant conflicts.

(28) Where a staff member is unsure about whether they have a conflict of interest they should seek advice from their supervisor in the first instance. Supervisors may seek advice from their Senior Leader or from the Integrity Unit if they require further clarification.

(29) If a conflict of interest ceases to exist, then the relevant staff member should advise their supervisor using the online disclosure tool ensuring the record is closed and no longer subject to a management plan.

Supervisors

Local Manager

(30) For the purposes of this Procedure, a Local Manager is a staff member appointed to Authority Level 4 under the UQ Human Resources Sub-delegations Schedules.

(31) In addition to the responsibilities in the ‘University Staff’ provisions, the Local Manager is required to:

1. Work with persons at or below Level 4 within their team(s) to refine management plans for conflicts that have been disclosed to them;
2. Recommend management plans for conflicts involving persons below Level 4 within their team(s) or organisation unit for Senior Leader approval;
3. Seek advice on how to manage conflicts of interest where necessary;
4. Ensure all staff in their team or Organisational Unit undertake annual conflict of interest self-assessment and disclosure; and
5. Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in clauses 26-27 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

Senior Leader

(32) For the purposes of this Procedure, a Senior Leader is a staff member appointed to Authority Level 3 or their nominee (not below level 4) under the UQ Human Resources Sub-delegations Schedules.

(33) In addition to the responsibilities in the ‘University Staff’ provisions, the Senior Leader is required to:

1. Review and approve where appropriate management plans that are recommended to them by a Local Manager;
2. Work with persons at or below Level 3 within their team(s) to refine management plans for conflicts that have been disclosed to them, and approve where appropriate;
3. Seek advice from the Deputy Vice-Chancellor (Research and Innovation) to formulate a management plan for a commercialisation or financial conflict of interest where appropriate; and
4. Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in clauses 26-27 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

Executive Leader

(34) For the purposes of this Procedure, an Executive Leader is a staff member appointed to Authority Level 2 under the UQ Human Resources Sub-delegations Schedules.

(35) In addition to the responsibilities in the ‘University Staff’ provisions, the Executive Leader is required to:

1. Work with persons below Level 2 within their team(s) to refine management plans for conflicts that have been disclosed to them, and approve where appropriate;
2. Approve and manage complex or sensitive disclosures or management plans that are referred to them by a Senior Leader, or otherwise referred; and
3. Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in clauses 26-27 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

Vice-Chancellor and President

(36) In addition to the responsibilities in the ‘University Staff’ provisions the Vice-Chancellor and President is required to:

1. Work with members of Executive Leader (Level 2) to refine management plans for conflicts that have been disclosed to them and approve where appropriate;
2. Approve and manage complex or sensitive disclosures or management plans that are referred to them by an Executive Leader, or otherwise referred; and
3. Monitor and manage any conflict of interest and management plan within the conflict of interest register (as described in clauses 26-27 of the Conflict of Interest Policy) involving staff under their supervision until a point in time when a conflict no longer exists.

Integrity Unit

(37) The Integrity Unit is responsible for:

1. administering conflict of interest training and maintaining the staff self-assessment tool;
2. investigating serious breaches of this Procedure and the University Staff Code of Conduct Policy in relation to conflicts of interest; and
3. maintaining records of all conflict of interest matters it investigates, including outcomes and any external referrals that have been made.

Section 5 - Monitoring, Review and Assurance

(38) The Provost and Chief Human Resources Officer is responsible for:

1. reviewing this Procedure regularly and in consultation with relevant stakeholders; and
2. raising awareness of the Conflict of Interest Policy and procedures across the University to build an organisational culture that supports supervisors and staff in its implementation.

Section 6 - Recording and Reporting

Disclosure and Management of Interest Register

(39) A University disclosure and management of interest register must contain:

1. conflicts of interest that have been disclosed using the disclosure tool; and
2. approved conflict management plans.

Section 7 - Appendix

Definitions and Terms