Managing conflicts of interest

• What is a Conflict of Interest?
• Identification of Conflicts
• Disclosing and Managing a Conflict of Interest

It is recognised that from time to time conflicts of interest in research will arise and that the mere existence of a conflict of interest does not imply wrongdoing.

In some cases it is possible and desirable to remove oneself from the identified conflict. At other times this is not possible and/or not desirable.

However, at all times it is important to ensure that such conflicts are identified, disclosed and managed in a rigorous and transparent way. This promotes public confidence in the integrity, legitimacy and impartiality of research undertaken by the University’s research staff and students.

What is a Conflict of Interest?

The Australian Code for the Responsible Conduct of Research (The Code) defines a conflict of interest as follows:

“A conflict of interest exists in a situation where an independent observer might reasonably conclude that the professional actions of a person are or may be unduly influenced by other interests. This refers to a financial or non-financial interest which may be a perceived, potential or actual conflict of interest.”

Researchers have a responsibility to: “Disclose and manage actual, potential or perceived conflicts of interest.” (The Code, R24)

It is important to recognise that conflicts of interest in research may be real, perceived or potential. Researchers must be conscious that a perceived conflict of interest could be as important as an actual conflict

Identification of Conflicts

Researchers should consider the potential for conflict in all possible interests. These interests may include but are not necessarily limited to the following:

• financial interests, including receiving cash, services, equipment or other recompense from external bodies to support research activities;
• consultancies;
• professional positions;
• membership of committees, advisory groups or boards of directors;
• family and personal relationships.

A conflict of interest may inappropriately affect, for example:

• collection, analysis, and interpretation of data;
• choice of protocol and/or statistical methods;
• sharing of results;
• hiring of staff;
• procurement of materials;
• choice of licensees.

Illustrative examples (adapted from information on the University of Oxford website) of situations that give rise to conflicts of interest in research include:

• A researcher has a financial interest in the company sponsoring the research. This conflict of interest would be further exacerbated if the value of the researcher's interest may be affected by the outcome of the research.
• A researcher is an inventor on a patent(s) or a creator of other IP whose value may be affected by the outcome of the research.
• A researcher takes part in the negotiation of a contract between the University and a company, where the researcher or his or her family or a close personal friend has a financial or non-financial interest (e.g. a directorship) in that company.
• The researcher holds a position in an enterprise (e.g. as director) that may wish to restrict or otherwise manage adverse research findings for commercial reasons or not wish to publish the results of the research.
• A researcher or a related body in which the researcher has an affiliation or a financial interest may benefit, directly or indirectly, from dissemination of research results in a particular way (including any unwarranted delay in or restriction upon publication of such results).
• A researcher conducts a clinical trial which is sponsored by any person or organisation with a financial interest in the results of the trial.
• A postgraduate research student conducts research on a project that receives support from a company in which the student or their supervisor has a financial interest or significant position.
• A researcher who has a senior editorial position with a commercial journal is also on a University library committee that recommends journal subscriptions.
• A researcher chairs a University committee which is to consider the allocation of funds to be shared between a number of Divisions/Schools, including their own.

Note: A conflict of interest may also exist where a researcher's spouse or immediate family member has any of these interests or involvements.

Disclosing and Managing a Conflict of Interest

The responsibility for identifying, understanding and managing a conflict of interest rests, in the first instance, with the individual.

Publications
Authors submitting a manuscript for publication should disclose:

• any financial supporters of the research
• any financial interest or other relationship with the manufacturers of any commercial products or providers of commercial services discussed in the manuscript.

This ensures readers are provided with the information upon which to make their own judgments.

Outside Work (Paid or Unpaid)
The University’s Outside Work Policy requires that written approval be sought from the appropriate line manager (head of school, director or senior manager) prior to a staff member engaging in Private Practice. Further, the approval of the Vice Chancellor is required prior to a staff member accepting an Outside Directorship.

The Policy states that outside work is not allowed where the staff member has, may have, or may reasonably be perceived to have a conflict of interest and, that if this situation occurs, the staff member must notify the appropriate line manager and take appropriate steps to remedy the situation in conjunction with them. The line manager may withdraw approval for the activity if necessary.

The Code
Strategies for addressing perceived or actual conflicts of interest should be discussed, agreed and documented between a researcher and their appropriate line manager.

Possible strategies (adapted from information on the University of Melbourne website) may include but are not limited to:

• Public disclosure of a researcher's financial interest in any research sponsor or the commercial success of any strategy, product or service that is the subject of any research results being reported.
• Monitoring of any research project by independent reviewers.
• Modification of any research proposal or plan.
• Disqualification of any researcher from participating in all or a portion of any sponsored research.
• Divestiture by a researcher of any financial interest in any research sponsor.
• Severance of any relationship between a researcher and a research sponsor which may create actual or potential conflicts of interest.

Other
Researchers need to be aware that some research funding agencies set specific disclosure requirements related to conflicts of interest. Further information can be found in the terms and conditions of the grant or contract.

Researchers should contact Research and Innovation Services if they are in any doubt as to the requirements.