Conflict of Interest Policy

Purpose:

To establish a consistent, transparent and risk-based framework for identifying, disclosing, assessing, managing, recording, monitoring and reporting actual, potential and perceived conflicts of interest across the University of Dubai (UD).

Scope:

This policy applies to every member of the University community whenever they act for, represent, advise, govern, study at, provide services to, or use the resources of UD. It applies regardless of employment or engagement type, location, funding source or whether the activity occurs during or outside normal working hours.

Members of the Board of Trustees, UD Council, standing and ad hoc committees, advisory boards, and any person exercising delegated decision-making authority.
Employees, faculty, students, visiting and adjunct academics, researchers, collaborators, interns and volunteers.
Consultants, contractors, suppliers, committee members and other third parties acting for or on behalf of UD.
Individuals granted access to UD property, information, systems, services, funds, facilities or infrastructure.
This policy governs conflicts of interest. It does not replace the specific approval, conduct, procurement, research, employment, disciplinary, grievance, appeal, whistleblowing, anti-bribery or records requirements in the related policies listed below.

For this policy, “University community member” means any person within the scope above. The obligation to disclose applies even where the individual believes that the conflict can be managed or would not affect the decision.

Definitions and abbreviations:

Term	Definition
UD	University of Dubai
Conflict of interest	A situation in which a private, financial, professional, academic, family, personal or other interest could improperly influence, or could reasonably be perceived to influence, the objective performance of a UD duty or decision.
Actual conflict	A current conflict between a University duty and a private or competing interest.
Potential conflict	A situation that could develop into an actual conflict.
Perceived conflict	A situation in which a reasonable and informed person could conclude that a conflict exists, whether or not it actually does.
Conflict of duty	Competing duties owed to UD and another organization, body, client, sponsor or public office.
Related person or entity	A family member, household member, close personal associate, business partner, controlled entity, employer, client, sponsor or other party whose interests may reasonably be linked to the member.
Recusal	Complete withdrawal from discussion, access to relevant non-public information, evaluation, recommendation, approval, decision and implementation concerning the affected matter.
Management plan	A written record of the assessed risk, treatment, responsible owner, restrictions, monitoring frequency, review date and closure criteria.
Significant or high-risk conflict	A conflict involving senior governance, material financial or reputational exposure, procurement, recruitment, promotion, assessment, research integrity, regulatory reporting, confidential information, or a matter that cannot be adequately managed at unit level.

Roles and Responsibilities

Roles	Responsibility (RASCI)
Human Resources Department (HRD)	Responsible for the institutional disclosure process, central register, guidance, annual declarations, management-plan monitoring, secure records, training and consolidated reporting.
President / Governance, Risk and Audit Committee (GRAC)	Accountable for senior-level and significant conflicts, independent oversight, receipt of institutional reports and escalation to the Board of Trustees where required. A conflicted person must not participate in their own case.
Managers, Deans and Functional Control Owners	Responsible for prompt escalation, initial risk assessment and implementation of approved controls. Research, procurement, recruitment and other specialist matters must also follow the relevant functional policy and control owner.
All University Community Members	Responsible for timely, complete and continuing disclosure; recusal pending assessment; compliance with management plans; and reporting material changes.
Quality Assurance and Institutional Effectiveness (QAIE)	Provides periodic process assurance and policy-alignment review. QAIE does not own individual cases, approve conflicts or replace HRD, management, GRAC, internal audit or disciplinary decision-makers.

Activity	HRD	President / GRAC	Managers / Functional Owners	Community Member	QAIE
Identify and disclose a conflict before participation	I	I	C	R/A	I
Administer annual and event-driven declarations	R/A	I	C	R	S
Record disclosures in the central register	R/A	I	I	I	I
Assess ordinary unit-level conflict and approve plan	C	I	R/A	C	I
Assess research, procurement or recruitment conflict	C	I	R/A	C	I
Assess senior-level or significant conflict	R	A	C	I	I
Implement recusal and other approved controls	C	I	R/A	R	I
Monitor, review and close management plans	R/A	I	R	R	I
Escalate suspected non-disclosure or breach	R	A	R	I	I
Prepare annual anonymized institutional report	R	A	C	I	C
Provide periodic process assurance	C	A	C	I	R
Ensure confidentiality, retention and controlled access	R/A	I	C	I	C
Route disciplinary, grievance, appeal or whistleblowing matters	R	A	C	I	I

Policy

1. Principles

University community members must act impartially and in UD’s best interests. They must not use their position, information, authority or University resources for improper advantage.

A. Any actual, potential or perceived conflict must be disclosed before the person takes part in the affected matter.

B. A conflict is not automatically misconduct. Failure to disclose, incomplete or misleading disclosure, breach of an approved management plan, concealment, obstruction or retaliation may constitute misconduct.

C. No person may assess, approve, monitor or close their own conflict. An appropriately authorized and unconflicted person must make the decision.

D. If a person is unsure whether a conflict exists, they must disclose it.

2. Relationship with Other Policies

This policy governs the disclosure, assessment, management and recording of conflicts of interest. Where another University policy applies to the related activity, that policy continues to govern its approval and operating requirements. Following this policy does not replace any separate approval or duty required under another University policy.

Conflicts may arise from personal or related-party interests, employment decisions, procurement, gifts or hospitality, outside activities, research, or the use of University information and resources. A conflict may exist when a personal interest could affect, or appear to affect, a person’s fair judgment.

3. Identifying and Disclosing a Conflict

a. When disclosure is required:

Before appointment, engagement or committee participation, where relevant.
Each year by the President, employees, faculty and roles identified by HRD as higher risk.
As soon as a new conflict arises or an existing conflict changes.
Before taking part in an affected decision, transaction, assessment, recruitment, procurement, research, funding or approval process.

b. Immediate Protection

Until the conflict is assessed, the person must not access restricted information, influence the matter, make a recommendation or decision, approve spending, supervise the affected process, or represent UD in relation to it.

c. Information Required

A disclosure must be complete and provide enough information for the University to understand and assess the conflict. It should identify the interest, the affected University activity or decision, the people or organizations involved, relevant dates, any financial or non-financial connection, and any immediate action already taken.

d. Submission and Central Record

All disclosures must be submitted through the University’s approved disclosure process and recorded in the central Register of Disclosed Interests maintained by HRD. The Register shall contain sufficient information to demonstrate the disclosure, assessment, decision and any required management action.

An ordinary unit-level matter may be coordinated by a Manager or Dean, but it must not remain only as an informal or local record. A matter beyond the person’s authority or independence must be escalated immediately.

e. Senior and Significant Conflicts:

Conflicts involving senior leadership, governance bodies, significant institutional risk, or a case in which the normal decision-maker is conflicted must be referred to an appropriate unconflicted authority under the University’s governance and delegation arrangements.

f. Special Conflicts

Research, procurement, recruitment and other specialist conflicts must also follow the relevant University policies and controls listed in related documents. The same disclosure does not need to be submitted twice where approved systems share the necessary information, but the responsible control owners must receive the information needed to perform their duties.

4. Assessing and Managing a Conflict

A formal written management plan should be required where the nature or significance of the conflict reasonably requires ongoing controls. For straightforward cases, the decision and agreed action may be recorded through the approved disclosure process. The person who disclosed the conflict may be consulted but must not approve the outcome.

The management plan must state the approved controls, responsible owner, monitoring arrangements, review date and closure requirements. Depending on the risk, the University may:

Avoid or remove the conflict through recusal, reassignment, disposal of the interest, withdrawal from the activity, replacement of the decision-maker, or ending the conflicting arrangement, subject to contract and law.
Reduce and control the conflict through restricted duties or information access, independent review, separation of duties, competition, added approvals, supervision, limited participation or time limits.
Appoint an independent and unconflicted person, panel or control function to oversee the matter.
Retain a low-risk potential or perceived conflict only where the written assessment shows that no stronger control is reasonably required. The reasons, conditions and review date must be recorded.

An unmanaged actual conflict, self-approval or high-risk matter must not be retained without effective controls.

5. Monitoring, Reporting & Assurance

a. Monitoring

HRD and the management-plan owner must review open cases at the frequency stated in the plan and at least once each year. The person must report any change immediately. Each review must confirm whether the controls remain effective and record continuation, amendment, escalation or closure.

b. Institutional Reporting

HRD must track required annual declarations and prepare an anonymized annual report.

The report must be provided to the President and Risk Audit Committee. Reports must exclude unnecessary personal information. Case-level details may be provided only where needed for lawful oversight, investigation, risk treatment or decision-making.

c. Assurance & Audit

Internal Audit or another authorized audit body may conduct an independent review. Access to personal case information must be limited to what is necessary for the authorized review.

6. Non-Compliance

Failure to disclose a conflict, providing false or misleading information, breaking an approved management plan, concealing a conflict, obstructing a review, or retaliating against another person may be treated as misconduct. Corrective, disciplinary, contractual, legal or regulatory action may be taken under the applicable University policy and law.

Suspected concealed conflicts, bribery, corruption or retaliation may be reported under the Whistleblower Policy. Grievances, appeals and disciplinary matters must follow the relevant University policy listed in the Related Policy section.

7. Privacy, Confidentiality and Records

Conflict-of-interest information is sensitive. It may be collected, accessed, used, shared, retained and disposed of only for legitimate governance, legal, risk, employment, research, procurement, audit, accreditation or disciplinary purposes, in line with applicable law and University information-governance requirements.

Access is limited to people who need the information to assess, approve, implement, monitor, assure, investigate or report the matter.
A manager must not promise absolute confidentiality.
The person who disclosed the conflict must be informed of the decision and their duties.
Other affected people must receive only the information needed to apply the controls or protect procedural fairness.
HRD must keep an auditable record of each disclosure, assessment, decision, approval, recusal, management plan, review and closure.
Records must be protected and retained under the University’s approved records-retention requirements and applicable law.

Immediate and substantial risks, senior-level conflicts, suspected misconduct, and matters outside local authority must be escalated promptly to HRD and the appropriate unconflicted authority. A disclosure must not be routed to a person involved in the matter.

8. Awareness Training

HRD must provide conflict-of-interest guidance during employee induction.

9. Policy Interfaces

The following activities may create a conflict of interest but are governed in detail by their own approved policies. This policy requires disclosure and conflict management; it does not grant approval for the activity.

Activity	How the policies work together
Outside employment, consultancy, research and fellowship	Disclose and manage the conflict under this policy. Obtain any separate approval required under FP 5.24, FP 5.22, FP 5.38 and the applicable research policy.
Recruitment, employment of relatives, promotion, remuneration, assessment and supervision	Disclose and manage the conflict under this policy. Follow FP 5.21, FP 5.02, FP 5.13 and other applicable employment controls.
Gifts, hospitality, travel and benefits	Disclose and manage any conflict under this policy. Follow PDI 10.08 and FP 5.22 for acceptance, reporting and other controls.
Procurement and suppliers	Disclose before accessing bids or taking part in evaluation or award decisions. Follow the applicable procurement policy and controls.
Research	Disclose the interest through the approved channel and follow the applicable research-integrity, ethics, funding and commercialization controls.
Wrongdoing, grievances, appeals and discipline	Use the process in the relevant Whistleblower, Grievance, Appeals or Disciplinary Policy. This policy does not replace those procedures.

Policy Review

This policy shall be reviewed at least every three years, and earlier following a material legal or regulatory change, audit or accreditation finding, significant breach, governance change, recurring implementation issue, or amendment to a related policy.

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