PQA Applicant Conflict of Interest Policy
The PQA Applicant Conflict of Interest Policy follows that in use by the lead partner: https://www.gla.ac.uk/research/strategy/ourpolicies/conflictsofinterest/
This Policy applies to all Applicants for the Photonics and Quantum Accelerator of Impact and Community Engagement projects.
The purpose of this Policy is to protect the PQA from any appearance of impropriety and thereby safeguard its reputations and that of the Partners. This Policy also enables the PQA to comply with their legal and contractual obligations to third parties (such as research funders).
All Applicants are responsible for:
- identifying situations in which they have a conflict of interest or where there is potential for a conflict of interest to arise;
- disclosing such situations to the PQA Project Manager; and where required, taking appropriate measures to manage the conflict of interest in accordance with the general procedures below.
Identifying a conflict of interest
Each Applicant is responsible for identifying situations in which they have a conflict of interest or where there is potential for a conflict of interest to arise.
A conflict can occur when the Applicant’s application competes with their personal interest, personal relationships, or duties to others. This can include situations where the commitments and obligations owed by the Applicant to their University or to other bodies, for example a funding body, are likely to be compromised or may appear compromised by:
- personal gain, or gain to immediate family (or a person with whom the member of staff has a close personal relationship), whether financial or otherwise; or
- the commitments and obligations that the member of staff owes to another person or body.
A conflict can be actual, potential, or perceived. A perceived conflict of interest is one which a reasonable person would consider likely to compromise objectivity. A potential conflict of interest is a situation which could develop into an actual or perceived conflict of interest.
A conflict of interest may be financial or non-financial, or both.
If an Applicant is unsure about whether a particular situation amounts to a conflict of interest (actual or potential), they should disclose that situation.
Some examples of potential conflicts of interest are listed below. This list is not exhaustive.
Disclosing a conflict of interest
Each Applicant must disclose to the PQA Project Manager any situation in which they have identified a conflict of interest (actual or potential) as soon as possible after identifying the conflict of interest. If the conflict is potential, the Applicant must not wait until the conflict actually arises; they must disclose the potential conflict as soon as they identify it.
An Applicant shall make their disclosure by emailing the PQA Project Manager, after indicating the conflict during the application process.
Management of a conflict of interest
The Steering Committee will evaluate any disclosure made by an Applicant and may decide either that:
- Disclosure of the conflict is sufficient; or
- Additional measures may be required to manage the conflict in order to protect the PQA and/or the Reviewer.
In cases where the Steering Committee has decided that additional measures may be required to manage the conflict, they will decide on the appropriate measures to be taken following discussion with the Applicant. The discussion with the Applicant shall take the form of a Conflict Management Plan.
The Conflict Management Plan will detail the conflict of interest, any additional actions to be taken and will include a suitable review date. This information will be kept on file for as long as the conflict of interest exists.
The PQA Project Manager will discuss and inform the Applicant of any additional measures that are required to manage the conflict, which may include:
- the Applicant not taking part in reviewing applications for this Call
- the Applicant not taking part in reviewing applications for any future Calls
- the Applicant not being able to apply for funding in this Call
- the Applicant not being able to apply for funding in any future Calls
Decisions of the Steering Committee will be recorded in the conflicts of interest register with a review date set.
Applicants are required to comply with any additional measures put in place to manage the conflict of interest and failure to comply may result in disciplinary action.
Anyone who is concerned that an Applicant may have an undisclosed conflict should raise this with the PQA Project Manager.
Information provided by Applicants regarding conflicts of interest under this Policy and any measures required in relation to conflicts of interest will be recorded on a register of interests.
Examples of potential conflicts of interest
This list is not exhaustive, and Applicants should consider their own particular circumstances. Applicants should ask themselves if others (e.g. managers, students, customers, colleagues, members of the public) would trust their judgement if they were in possession of the facts of the interest: could others reasonably conclude that it might influence the Applicant to act other than in the interests of the PQA? Advice may be sought from the PQA Project Manager in the first instance.
A close relative or immediate family can be defined as: spouse, civil partner, or a financial dependent. However, the ‘close personal relationship’ giving rise to an interest could extend to the following (this is not intended to be an exhaustive list): unmarried partner, parent, all children, siblings, grandparent, grandchild, mother-in-law, father-in-law, sister-in-law, brother-in-law, son-in-law, daughter-in-law, the (unrelated) child of an unmarried partner, as well as half and step members of family.
Examples
The Applicant, or their spouse, partner, close relative, or business partner has interests such as:
- Business position such as Directorships, including non-executive directorships of, or employment by, public or private companies likely or possible seeking to do business with the PQA.
- Significant shareholdings in public or private companies or ownership or part-ownership of or employment by businesses or consultancies likely or possibly seeking to do business with the PQA.
- Any other personal or financial interest (including shareholding) in a company or other organisation with which the PQA is negotiating or holds a contract or is engaged in any other business transaction.
- Remunerated or honorary positions and other connections with HE institutions which may give rise to a conflict of interest.
- A personal financial interest (e.g. licence income) in a PQA-related activity.
- Membership of an external committee or body whose work may relate to that of the PQA (for example, committees or bodies set up by research councils, other funding bodies, school boards, government departments, NHS trusts).
An Applicant who has a spouse or partner who is also an Applicant, in cases where they may work together on matters affecting the PQA’s business.