Conflict of Interest policy

It is Crick practice to encourage and foster external activities, whilst ensuring that when conflicts or perceived conflicts of interest arise, they are acknowledged, disclosed, and in relevant cases appropriately managed. Actual or perceived conflicts of interest can arise inside the workplace too and should be dealt with in a similar way.

Conflicts or perceived conflicts of interest are those, whether of a financial or non-financial nature, that could influence or undermine the objectivity, impartiality, and/or integrity of the Crick, as well as an individual.

A conflict of interest may be in relation to financial and/or research interest, and/or a close personal relationship.  It is not possible to define all circumstances, but the following examples are intended to provide you with some guidance.  Please note, this list is not exhaustive and the examples would also apply to any interest of a member of your immediate family or another person with whom you have a close personal connection:

Close personal relationships

• You have a close family member or are in a close personal relationship with someone at the Crick or at one of our Founders (Cancer Research UK, Medical Research Council, Wellcome, UCL, Imperial College London and King's College London).

Financial interests

• You work for and are paid by another organisation or institution that could present a conflict of interest either financially and/or in research.
• You are a director of an external company or hold shares in that company and engage the services of that company to supply to the Crick.
• You stand to make a personal gain from an opportunity at the Crick.
• You take part in negotiating a contract between the Crick and an external organisation that you have an interest in.
• You have a board position, advisory or consultancy role, or financial interest:
  • in an organisation that is engaged in activities closely related to your work or research at the Crick.
  • in the business ventures of a junior colleague or student.

Research interests

• You are a researcher who holds a board position, advisory or consultancy role, or financial interest in an organisation that:
  • may wish to restrict, delay or otherwise influence the positioning of adverse research findings for commercial reasons.
  • may benefit, directly or indirectly, from the dissemination of research results in a particular way or at a particular time.
• You are involved in a clinical trial or research programme which is subject to terms set by a company in which you hold an interest.
• You have set up a spin-out company which is closely related to your area of research.

Staff supervision and teaching

• You have a close personal relationship with a student or a member of their family and are marking a piece of the student’s assessed work, and/or are involved in considering that student for an award or prize.
• You accept a gift from a student, collaborator, or worker, prior to an assessment or review.
• You use your student for work relating to an external interest.

This Policy applies to all employees and students on Crick terms and conditions and anyone whose activity falls within the definition of NIH Investigator.

NIH Investigators are the project director or principal investigator or any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the US Public Health Service (and any of its components including the US National Institutes of Health (NIH)), or proposed for such funding, which may include, for example, collaborators or consultants. 

All Crick employees, students, and any NIH Investigator, are required to disclose activities and relationships that might give rise to a conflict of interest or the perception of a conflict. 

Those whose activities fall within the definition of NIH Investigator should read the Addendum.
 

If you are a manager, you must also ensure that your team/lab members complete the declaration of interests form when asked to do so.

By disclosing these, the Crick can ensure that such real or perceived conflicts are appropriately managed or avoided. If properly managed, activities or personal circumstances can usually proceed as normal whilst at the same time upholding the manager's obligations to the Crick.

Appropriate management of any risks or perceived risks will enable the Crick to meet regulatory (i.e. Federal Financial Conflict of Interest) and other external requirements and protect the integrity and reputation of the Crick and our Founders (Cancer Research UK, Medical Research Council, Wellcome, UCL, Imperial College London and King's College London).

By contrast, conflicts which are not managed effectively may jeopardise the Crick’s public standing and may cause serious damage to the reputation of the institute and of the individuals concerned.

If you have a conflict of interest to declare but refuse to declare this after being reminded by the HR team, this could lead to you being invited to attend a disciplinary meeting. A member of the HR team will have a conversation with you and encourage you to complete the online form before this happens. 
 

Crick employees and students are required to declare any potential or perceived conflicts of interest upon starting their role at the Crick, and thereafter on an annual refresh basis by completing a declaration of interests form.  It is also the responsibility of managers to disclose any further interests as and when they arise, without delay to the Chief People Officer.  

Anyone submitting an application for NIH funding or otherwise falling within the definition of NIH Investigator will also be required to declare any potential or perceived conflicts of interest, and thereafter on an annual refresh basis for the period of the award.  Additionally, NIH investigators will be required to undertake Financial Conflict of Interest (FCOI) awareness online training.  

The information provided in the declaration of interests form will be processed in accordance with the information security policy and all current Data Protection legislation.  

Save as permitted or required by law, information will not be shared outside the Crick without the individuals’ permission, although the details will be included in a Register of Interests, which will be open to inspection by the Crick’s auditors and other authorised parties.

To help you understand your obligations under this Policy, the following training materials are available:

• Identifying conflicts of interest
• Types of conflict of interest

Anyone whose activities falling within the definition of NIH Investigator must undertake Financial Conflict of Interest (FCOI) awareness online training.  

The Sponsor is responsible for ensuring that this Policy is reviewed regularly and updated to align with external legislative, regulatory and other developments and to reflect current best practice. 

• Addendum to the Crick conflict of interest policy: NIH Financial Conflict of Interest (FCoI)
• Conflict of interest
• Declaration of interests form

If in any doubt as to your obligations, you should speak to your manager or the Policy Owner. 

• Addendum to the Crick conflict of interest policy: NIH Financial Conflict of Interest (FCoI)
• Disciplinary policy
• Information Security policy

The Crick is committed to the highest standards of safety, transparency, probity and accountability. You can raise any questions or concerns with your manager or with the Policy Owner in the first instance. However, if you have any serious concerns relating to existing, previous or likely acts of malpractice at the Crick, the Whistleblowing Policy provides a clear, confidential mechanism for reporting your concerns and describes the steps the Crick will take to addressing and reporting back on them.