/Institutions/University-of-Dubai/json/2024-2025/Policy-and-Procedure-Manual-local.json

/Institutions/University-of-Dubai/json/2024-2025/Policy-and-Procedure-Manual.json

Policy and Procedure Manual 2024-25 > Legal Compliance and Public Disclosure > Conflict of Interest Policy

Conflict of Interest Policy

Policy

1. All university members must ensure that there is no actual or perceived conflict between their personal interests and their University duties or responsibilities. UD expects that all members recognize, declare and appropriately manage conflicts of interest.

2. In accordance with the UD Code of Conduct, UD expects that its staff members will uphold community confidence in the integrity of its administration and acknowledge the primacy of the public interest, and undertake that any conflict of interest issue will be resolved or appropriately managed in favor of the public interest.

3. UD recognizes that a well-established system for identifying, disclosing and managing conflicts of interest increases its public accountability and reduces the risk of corruption, misconduct and bias in its operations and decision-making processes.

4. All UD staff members have a duty to comply with the ethics value of integrity and impartiality defined in the UD Code of Conduct. 

5. UD expects that all conflicts of interest, regardless of their character or level, will be properly identified, disclosed, managed and monitored.

6. The University recognizes that conflicts of interest are not unusual in the exercise of public responsibility, and cannot always be avoided.

7. Conflicts of interest may be actual, potential or perceived, and may be pecuniary or non-pecuniary in nature.

1. Roles and responsibilities

1. HR Department
   The Human Resources department is responsible for the overall management of conflicts of interest processes within the University.

2. All University community members
   All UD-community members are responsible for identifying and formally disclosing any interests which may result in a conflict with their duties and responsibilities at UD. UD-community members with such interests should not seek to influence, directly or indirectly, the advice provided by, or actions of, management and administration in matters relating to the interest. In the case where a UD-community member is a member of a UD committee with voting rights, he/she shall forfeit the right to vote on the matter in conflict.

3. Managers and Deans

Department managers and academic deans are responsible for ensuring that UD-community members are aware of the University's requirement for disclosing conflicts of interest, and for managing, recording and monitoring any disclosures made by their staff.

1. Identifying conflicts of interest

UD-community members must ensure that any conflicts between their personal interests and their University duties or responsibilities are promptly identified and managed. In seeking to identify if personal interests conflict with official duties, staff members should give consideration to:

1. The nature of the interest and the ambit of their official duties.

2. Whether the interest could appear to a reasonable person to influence the UD-community member’s performance of their official duties, including any decision-making authority.

In the event that a UD-community member is uncertain whether a conflict of interest exists in accordance with the definitions of this policy, the member may seek advice from the department manager. However, to ensure that integrity and accountability requirements are met, the general expectation is that members should declare the situation as a conflict of interest in accordance with the requirements of this policy.

 

1. Disclosure of University-level conflicts of interest

Disclosures of conflict of interest must be managed at the University level if

1. They relate to a member of a University-level committee, including Council and its committees; or

2. The interest could impact on the University in general, either due to the nature of the conflict, or the duties of the UD-community member concerned.

 

University-level disclosures are formally submitted through email and information provided in such declarations is recorded in the University's Register of Disclosed Interests which is maintained by the HR. In addition, the HR maintains a Register of Significant and Reportable Gifts for disclosure of any gifts received during the course of a UD-community member's duties.

 

The University also maintains a Register of Disclosed Interests for Research for the disclosure of interests relating to research activities which shall be maintained by the Director of Research.

 

 

1. Disclosure of local-level conflicts of interest

Disclosures which do not relate to a University-level committee or will not impact on the University in general, should be recorded and managed at the local level by the department manager of the member concerned.

 

1. Managing Conflicts of Interest

The management of conflicts of interest at UD is based on the University’s Risk treatment strategy, and should be agreed on by the UD-community member concerned and their department manager. The four recommended treatments are as follows:

 

1. Avoid the Conflict of Interest
   Avoiding a conflict of interest which poses an unacceptable risk to, or impact on, the University's interests is the preferred and recommended strategy. To avoid a conflict of interest, the member concerned may be removed from the decision-making process in relation to the matter concerned or requested to relinquish the private interest which is creating the conflict.

2. Accept and Reduce the Conflict of Interest
   A conflict of interest may be reduced by ensuring that the member concerned has restrictions placed on his/her involvement in the relevant matter, or that another staff member or organizational area takes responsibility for the matter.

3. Share the Conflict of Interest
   A conflict of interest may be shared by involving a third party to oversee part or all of the decision-making process that deals with the relevant matter.

4. Retain the Conflict of Interest
   A conflict of interest may be retained and the member continues to be involved in the matter concerned, subject to regular review of the situation. This treatment is only suitable for low risk potential or perceived conflicts of interest.

 

1. Monitoring Conflicts of Interest

All disclosed interests should be reviewed by the UD-community member and his/her department manager at least on an annual basis to ensure that the information remains correct, and that management treatments continue to be appropriate and effective.

 

1. Failure to Disclose an Interest

UD-community members have an obligation to declare and manage actual and perceived conflicts of interest. For staff members, failure to disclose an interest will be a breach of the UD Code of Conduct and subject to the processes of non-compliance as outlined in the Code. Other individuals who do not comply with conflict of interest disclosure requirements may have their association with UD terminated.

 

1. Privacy and Confidentiality

In line with UD’s information privacy policy, the personal information recorded as a result of disclosure of conflicts of interest remains strictly confidential and will only be further disclosed in the following circumstances:

1. A UD-community member must discuss any conflicts of interest with his/her department manager to ensure a proper management strategy is put in place;

2. It is a requirement that Ethics and Values committee members are made aware of any disclosures made by members;

3. The President receives an annual summary report on the Register of Disclosed Interests, the Register of Disclosed Interests for Research, and the Significant and Reportable Gifts Register;

4. The department manager is required to inform the HR Officer of any conflicts of interest that present immediate and substantial risks to the University and its operations.