Stonebridge University is committed to upholding the highest integrity, transparency, and accountability standards in all its academic, administrative, and operational activities. The university recognises that conflicts of interest can arise in various situations and may affect the ability of individuals to make impartial decisions in the best interests of the university. This Conflict-of-Interest Policy outlines the procedures for identifying, declaring, and managing conflicts of interest to ensure that all university activities are conducted ethically and transparently.

The policy provides a framework for maintaining trust and confidence in the university’s governance, research, and teaching practices. It applies to all university community members, including staff, students, and external partners. It aims to create an environment where potential conflicts of interest are managed appropriately and effectively.

The primary purpose of this Conflict-of-Interest Policy is to:

• Define what constitutes a conflict of interest and provide examples of different types of conflicts.
• Establish procedures for declaring, recording, and managing conflicts of interest.
• Promote transparency and fairness in decision-making processes across the university.
• Protect the reputation and integrity of Stonebridge University by preventing and addressing conflicts that could undermine its operations or values.
• Ensure staff, students, and external partners understand their responsibilities concerning conflicts of interest.

This policy is intended to support individuals in recognising potential conflicts and provide guidance on managing them appropriately, thereby fostering a culture of openness and accountability within the university.

This Conflict-of-Interest Policy applies to:

• All staff members, including academic, administrative, research, and support staff.
• All students, including undergraduate, postgraduate, and doctoral students.
• External partners and contractors working with or on behalf of the university.
• Members of the Board of Governors and other individuals involved in the governance or oversight of the university.

The policy covers a wide range of activities, including:

• Decision-making related to academic programs, student assessments, and research projects.
• Financial and contractual matters, including procurement and vendor selection.
• Employment, promotion, and recruitment decisions.
• Relationships with external organisations, partners, and stakeholders.

The policy does not cover personal grievances or complaints, which are addressed under separate policies, such as the Complaints Procedure or Disciplinary Policy.

4.1 What is a Conflict of Interest?

A conflict of interest arises when an individual’s personal, professional, or financial interests have the potential to interfere with their duty to act in the best interests of the university. A conflict of interest can be actual, perceived, or potential, depending on the circumstances.

• Actual Conflict of Interest: A situation where an individual’s personal interest directly affects their ability to perform their duties impartially.
• Perceived Conflict of Interest: A situation where an observer might reasonably believe that an individual’s personal interest could influence their decisions or actions.
• Potential Conflict of Interest: A situation where an individual’s personal interest could reasonably be expected to give rise to a conflict in the future.

4.2 Types of Conflicts of Interest

Conflicts of interest can take many forms, including:

• Financial Conflicts: Involving financial gain or loss, such as investments, gifts, or financial interests in contracts.
• Non-Financial Conflicts: Involving personal relationships, professional affiliations, or competing loyalties.
• Institutional Conflicts: Involving the university’s own financial or non-financial interests that could affect its decision-making processes.

4.3 Examples of Conflicts of Interest

Examples of conflicts of interest include, but are not limited to:

• A staff member participating in a hiring decision involving a family member or close friend.
• A researcher with a financial interest in the outcomes of their research project.
• A staff member receiving gifts or hospitality from a vendor seeking to do business with the university.
• A student serving as a teaching assistant in a course where their relative is enrolled.

4.4 Persons Who May Be Affected by a Conflicts of Interest

The following persons are required to read and abide by this policy:

• All employees of Stonebridge University.
• All contracted examiners and moderators.
• All those attending a Stonebridge University Assessment Board, regardless of whether they are in attendance as a member or observer.
• All attending Stonebridge University Academic Board.
• All teaching, support, and senior management staff are employed by centers.

4.5 Circumstances in which a Conflicts of Interest must be declared

A conflict of interest should be declared in the circumstances below; if in doubt, always declare it. 

Type A: When…

• You,
• your spouse,
• your child,
• another relative, a close friend,
• a person to whom you have obligations, whether personal, financial, and so on (examples might include employers or someone to whom you are in debt).

 …are registered on, or taking a course leading to, a Stonebridge University qualification with which you be involved, whether through teaching, administering, or assessing.

Type B: When a person from the list above [Type A] or a company they represent is under consideration for a Stonebridge University contract or position at a center, and you influence the making of that decision. Examples would include procurement of goods or services from external providers, appointment of teaching staff, and so on.

Stonebridge University’s approach to managing conflicts of interest is based on the following principles:

5.1 Transparency and Disclosure
All university community members are required to disclose any actual, perceived, or potential conflicts of interest as soon as they arise. Full transparency helps ensure that conflicts are identified and managed before they influence decision-making processes.

5.2 Integrity and Fairness
The university is committed to ensuring all decisions are made with integrity and fairness. This means that individuals must act in the university’s best interests and avoid situations where their personal interest’s conflict with their duties.

5.3 Confidentiality
All disclosures of conflicts of interest will be treated with the highest level of confidentiality. Information about conflicts will only be shared with those directly involved in managing the conflict and will be handled under data protection regulations.

6.1 Responsibilities of All Staff and Students

• Identify and disclose any conflicts of interest as soon as they arise.
• Participate in conflict management processes as required.
• Comply with any decisions or actions taken to manage or resolve conflicts.

6.2 Responsibilities of Senior Management and the Board of Governors

• Oversee the implementation of the Conflict-of-Interest Policy and ensure compliance across the university.
• Provide guidance and support to staff and students in managing complex or sensitive conflicts.
• Review and approve conflict management plans as required.

6.3 Responsibilities of the Conflict-of-Interest Committee

• Review all conflict-of-interest disclosures and determine appropriate management strategies.
• Provide independent oversight of the university’s conflict management processes.
• Maintain records of conflicts and ensure that they are managed consistently and effectively.

7.1 Identifying a Conflict of Interest
All university community members are encouraged to consider whether their personal, professional, or financial interests could affect their ability to perform their duties impartially. If in doubt, individuals should seek advice from their line manager or the Conflict-of-Interest Committee.

7.2 Procedures for Declaring a Conflict of Interest
Conflicts of interest must be declared in writing using the university’s Conflict of Interest Declaration Form, available on the university’s website. The form should include:

• A description of the conflict.
• The potential impact of the conflict on university activities.
• Any actions taken to mitigate the conflict.

Once the form is submitted, the Conflict-of-Interest Committee will review it and determine the appropriate management strategy.

7.3 Recording and Monitoring Declarations
All conflict-of-interest declarations will be recorded in a central register maintained by the Conflict-of-Interest Committee. The register will be reviewed annually to ensure that conflicts are managed effectively and that any changes in circumstances are considered.

8.1 Strategies for Managing Conflicts of Interest
The university will implement appropriate strategies to manage conflicts of interest based on their nature and severity. Strategies may include:

• Recusal: The individual with the conflict is excluded from decision-making processes related to the conflict.
• Disclosure and Transparency: The conflict is disclosed to relevant parties, and decisions are made transparently.
• Restriction of Activities: The individual’s involvement in activities related to the conflict is restricted or modified to reduce the potential impact on decision-making.
• Reassignment: The individual’s responsibilities are reassigned to another person to prevent the conflict from affecting their work.
• Third-Party Oversight: An independent third party is appointed to oversee decisions and ensure they are made impartially.
• Divestment or Resignation: In cases where a conflict cannot be effectively managed through other means, the individual may be required to divest their interests or resign from their position.

The Conflict of Interest Committee will work closely with the individual and their department to determine the most appropriate strategy based on the specific circumstances of the conflict.

8.2 Conflict Management Plans
A conflict management plan may be developed for more complex or ongoing conflicts of interest. The plan will outline the following:

• The nature of the conflict and its potential impact on university activities.
• The management strategy or strategies to be implemented.
• The roles and responsibilities of the individual and other parties involved.
• The process for monitoring and reviewing the conflict over time.

Conflict Management Plans will be reviewed and approved by the Conflict of Interest Committee and shared with relevant parties, including the individual’s line manager or academic supervisor.

8.3 Reviewing and Updating Conflict Management Plans
Conflict Management Plans will be reviewed regularly, at least annually, to ensure they remain practical and relevant. Reviews will consider any changes in the individual’s circumstances or the conflict. If necessary, the plan will be updated to reflect these changes, and the individual must sign off on the revised plan.

Stonebridge University takes non-disclosure of conflicts of interest and breaches of this policy very seriously. Failure to disclose a conflict or non-compliance with the agreed conflict management plan can undermine the integrity and credibility of the university’s operations. The university will take appropriate action to address non-disclosure or breaches following its disciplinary procedures.

9.1 Disciplinary Actions for Non-Disclosure
Failure to disclose a conflict of interest or provide false or misleading information may result in disciplinary actions, which could include:

• Formal warnings or reprimands.
• Suspension from duties or academic activities.
• Termination of employment or expulsion from the university, depending on the severity of the breach.

9.2 Consequences for Staff and Students
Staff and students violating the Conflict of Interest Policy will be subject to the university’s disciplinary procedures. Consequences may include:

• Exclusion from decision-making processes or research activities.
• Revocation of research funding or withdrawal from specific projects.
• Removal from leadership roles or responsibilities within the university.

9.3 Consequences for External Partners
External partners, contractors, or collaborators found to be in breach of this policy may face the following consequences:

• Termination of contracts or partnerships with Stonebridge University.
• Removal from preferred vendor or partner lists.
• Legal action, if applicable, to recover damages or enforce the terms of agreements.

The university will work to resolve policy breaches in a fair and transparent manner, aiming to protect its reputation and ensure that all parties act in accordance with the highest standards of integrity.

Stonebridge University recognises that certain activities and roles may present specific challenges in managing conflicts of interest. This section outlines the university’s approach to handling conflicts in sensitive areas, including research, financial matters, and procurement.

10.1 Conflicts of Interest in Research and Academic Integrity
Conflicts of interest in research can arise when a researcher’s personal or financial interests have the potential to influence the design, conduct, or reporting of research. The university is committed to upholding the highest standards of academic integrity and expects researchers to:

• Disclose any personal or financial interests that could affect their research.
• Refrain from engaging in research activities where a conflict cannot be managed effectively.
• Ensure that all research follows ethical guidelines and the principles of transparency and impartiality.

The Conflict of Interest Committee must review research funding from external organisations or individuals to ensure that it does not create a conflict or the appearance of bias.

10.2 Financial Conflicts of Interest
Financial conflicts of interest occur when an individual stands to gain financially from decisions or actions taken in their role at the university. To address financial conflicts, the university will:

• Require disclosure of all financial interests, including investments, consultancy roles, or board memberships, that could influence decision-making.
• Implement conflict management strategies, such as recusal from financial decisions or third-party oversight.
• Prohibit individuals from being involved in decisions related to procurement, contracts, or grants where they have a financial interest.

The Conflict of Interest Committee will review and record all financial disclosures and provide guidance on managing or eliminating conflicts.

10.3 Conflicts of Interest in Procurement and Contracting
Conflicts of interest in procurement and contracting can occur when individuals involved in selecting vendors, suppliers, or contractors have a personal or financial interest in the outcome. To prevent conflicts in this area, the university will:

• Request all individuals involved in procurement to declare any relationships or interests that could affect their impartiality.
• Prohibit staff members from participating in procurement decisions involving family members, close friends, or organisations in which they have a financial interest.
• Establish a separate oversight committee to review high-value contracts or those involving potential conflicts of interest.

The university’s Procurement Office will work closely with the Conflict of Interest Committee to ensure that procurement processes are fair, transparent, and free from bias.

The effectiveness of the Conflict of Interest Policy depends on the awareness and understanding of all university community members. To this end, Stonebridge University will provide regular training and development opportunities to ensure that staff, students, and external partners are fully informed about the policy and their responsibilities.

11.1 Staff Training Programs
All staff members will receive training on the Conflict of Interest Policy as part of their induction and on an ongoing basis. Training will cover:

• How to identify and disclose conflicts of interest.
• Strategies for managing conflicts in different contexts.
• The consequences of non-disclosure or breach of the policy.
• Case studies and scenarios to illustrate common conflicts and how to handle them.

Staff members involved in decision-making, research, procurement, or governance will receive additional training specific to their roles.

11.2 Student Awareness and Education
Students will receive information on the Conflict of Interest Policy during their induction and through the student handbook. The university will offer workshops and seminars to educate students on how conflicts of interest can arise in academic settings and how to manage them effectively.
Students engaged in research, student employment, or leadership roles will receive targeted guidance on managing conflicts in these contexts.

Stonebridge University is committed to monitoring the implementation of this policy and using conflict data to drive continuous improvement. Regular monitoring and reporting will ensure that conflicts of interest are managed effectively and that the policy remains relevant and responsive to emerging issues.

12.1 Monitoring and Reporting of Conflicts
The Conflict of Interest Committee will monitor the declaration and management of conflicts on an ongoing basis. Regular reports will be generated for senior management, highlighting:

• The number and nature of conflicts disclosed.
• The strategies used to manage conflicts.
• Any breaches of the policy and actions taken.

The university will use this information to assess the effectiveness of its conflict management processes and identify areas for improvement.

12.2 Using Conflict Data for Continuous Improvement
Data gathered from conflict disclosures and management will be used to:

• Develop new training and awareness initiatives.
• Revise policies and procedures to address emerging risks or gaps.
• Enhance support and guidance for staff and students in managing conflicts.

The Conflict of Interest Committee will work closely with other university departments to integrate conflict management into the university’s broader governance and risk management frameworks.

This Conflict of Interest Policy will be reviewed annually to ensure it remains aligned with best practices, legal requirements, and the evolving needs of the university community. Reviews will consider feedback from stakeholders, changes in regulatory requirements, and any issues identified through monitoring and reporting.
The review process will involve consultation with staff, students, and external partners to ensure that the policy reflects the diverse perspectives and needs of the university community.

Stonebridge University is committed to ensuring that the Conflict of Interest Policy is accessible to all university community members. The policy will be communicated through multiple channels, including:

• The university website will have the full policy document available for download.
• Staff and student handbooks will summarise the policy and critical points.
• Training sessions, workshops, and seminars on conflict management.

The policy will also be available in alternative formats, such as large print, audio, or translated versions, to accommodate individuals with specific needs or preferences.

When a conflict of interest is declared, the individual in question is expected to refrain from participating in any discussions or activities that the conflict may influence. “Recusing yourself” is the term used to describe this. The chair may request that an individual who has declared a conflict of interest but fails to excuse themselves depart a meeting. An individual who has declared a conflict of interest but fails to recuse themselves from activities related to a candidate involved in the admission or assessment process may be subject to disciplinary action. The institution will be expected to adhere to disciplinary proceedings if it employs such an individual. If the centre fails to comply, it may be subject to disaccreditation.

Incidents of malpractice and maladministration may be reported in the following ways:

By email: qtd@stonebridge.university

By post:
For the attention of the Director of Quality, Training and Development
Stonebridge University
6 Hill View Studios,
160 Eltham Hill,
London,
SE9 5EA

By phone: +44 7438 541824

Opening hours: 9:30am-5:30pm (UK) Mon-Fri

Stonebridge University staff members may use one of the methods above or confidently speak to the Director of Quality, Training, and Development.

Stonebridge University values integrity, transparency, and accountability in all its activities and interactions. The Conflict of Interest Policy is a key component of the university’s commitment to maintaining the highest ethical standards and ensuring that all decisions are made in the best interests of the university and its community.

By providing a clear framework for identifying, declaring, and managing conflicts of interest, the university aims to protect its reputation, promote a culture of openness and accountability, and support all community members in fulfilling their responsibilities ethically and effectively.
All university community members are encouraged to engage with this policy and seek guidance and support in managing conflicts of interest as they arise. Through collective efforts, Stonebridge University.