Conflicts of Interest and Annual Declaration of Interests

Registering interests is just one of the ways we are working to uphold our commitment to integrity under the Ethics Code. 

This is not intended to inhibit academic freedom or external engagements. As a community with extensive involvement outside LSE, we need to make sure we understand and manage any potential risks to the School. Many of these interests will not compete with your duties and responsibilities to the School. However, where your obligations to the School are, or may appear to be, compromised a conflict of interests occurs. 

Who needs to complete a declaration? 

New staff: We advise all new staff to complete a declaration as part of their induction.   

Staff who have an outside interest: All staff should complete a declaration as and when any interests arise or change. 

Decision making panels: Where staff are involved in staff recruitment panels or procurement panels, they should ensure they have completed a declaration. 

Particular groups of staff: Some staff are also required to complete a declaration annually, even when they have no interests to declare.  These groups of staff include: 

• SMC Members
• Council Members and Members of Council Committeess
• Staff at grade 10 and above 
• Department/Institute/Research Centre Managers  
• Senior staff in Professional Services Divisions 

We will communicate annually to all staff required to complete an annual declaration with a reminder to do so. 

What should I declare? 

You should declare: 

• Any roles in other organisations (including other universities) including employment, consultancy, board membership, company director or charity trusteeships. 
• A personal relationship with someone who has a contract supplying services to the School.
• Personal relationships with others working or studying at the School.
• Any property which you rent, lease or sell to or from the School. 
• Any grants or donations that have not been received through the usual School processes. 

 Further information on what you should declare, and what does not need to be included in your declaration is included in the Declarations of Interest Guidance (PDF).  

How do I complete a declaration?

You can make a declaration of interests at any time using MyView. Information on how to access the form in MyView can be found here: MyView DOI Guidance. 

What should I do after completing my declaration? 

All staff should complete a Declaration of Interest form and inform their Head of Division or Department where they have an interest that may conflict with their role at the School. Whilst the declaration is important, it does not replace the need for all staff to declare other relevant interests as they arise.  For example, if you are at a meeting where the School’s relationship with a particular supplier is discussed, and your partner works for that company, this should be declared even if the School already holds the information through your declaration response. 

The School acknowledges that there are a wide range of situations in which conflicts of interest may arise and encourages individuals to disclose potential conflicts so that they can be appropriately managed.

This relates to Principle 2 of our Ethics Code: Integrity

• Be honest and truthful
• Act in accordance with all relevant legislation and statutory requirements 
• Declare interests and appropriately manage possible conflicts
• Be transparent and consistent in our decision making
• Maintain our independence in engaging with outside parties

The Conflict of Interests Policy (PDF) defines potential conflicts, how they should be declared and appropriate resolutions.

Examples of conflicts of Interest include:

1. A relative or close friend of a manager reports directly to them.  The manager is responsible for determining their job responsibilities, pay and promotions.  
2. A manager is in a relationship with an employee who reports to them.
3. Trustees would be in conflict if they stood to benefit financially or otherwise from the School.
4. A member of an interview panel is a relative or close friend of one of the applicants and fails to disclose the relationship.
5. A member of staff involved in procurement of services selects the business of a family member to provide services to the School.
6. Where outside interests or commitments conflict with the role or commitments to the School.
7. The use of the School’s facilities to pursue external business or consulting activities.
8. A member of staff also serves on the Board of a funding body that is considering an application from the School.
9. A researcher has an interest in an organisation for which they are conducting research.
10. Involvement of a close friend, relative or partner in a research contract.

Declaring conflicts as they become apparent is essential if the process is to be effective. No one should participate in a decision in which they have a conflict of interests or might be seen to exercise bias. Instead, you should make the declaration and abstain from the decision taken. By failing to do so, you could be putting both yourself and the School at risk.

For further advice and guidance, please seek advice by emailing ethics@lse.ac.uk.

Each year (usually in the summer) the School undertakes an annual declarations exercise.  This is when we remind staff to complete a declaration.  Those staff who are invited to complete an annual declaration should complete the form, even to confirm you have no interests that require disclosure. If you have nothing to declare the survey should take no more than one minute. 

These groups of staff who will be included in the annual process are: 

• SMC Members
• Council Members and Members of Council Committeess
• Staff at grade 10 and above 
• Department/Institute/Research Centre Managers  
• Senior staff in Professional Services Divisions 

We will communicate annually to all staff required to complete an annual declaration with a reminder to do so. 

SMC, Council, Council committee members complete an annual declaration along with a fit and proper person declaration.  

Information on Council members' declaration of interests is available on the Council's webpage. 

What is an interest?

An interest can be a financial or non-financial interest.  All relevant interests listed in the Declarations of Interest Guidance (PDF) should be declared, even if there is no conflict.

What is a ‘conflict of interest’?

As stated in the School’s Conflict of Interests Policy, a conflict of interest arises where there is an actual or potential risk or a perceived conflict of commitments between acting in the best interests of the School and formal and/or informal commitments, obligations or undertakings to another body/association/affiliation in relation to the same or related matters, and those duties conflict.

In particular, a conflict of interest may arise where an individual might be seen to be influencing School matters for actual or potential personal benefit. For example, a situation where a member of staff is in a position to influence, directly or indirectly, School business, research or other decisions in ways that could lead to gain for them, their family or others.

No one should be involved in making decisions in relation to their commitments to the School from which they, or anyone with whom they have a close financial or personal relationship, stands to personally benefit. Such considerations apply to a wide range of activities, including, but not restricted to, student admissions, student assessment, disciplinary proceedings, appeals, staff recruitment, staff promotion and remuneration, procurement, and assessing proposed relationships between the School and outside parties

What should line managers do in relation to declarations made?

Line managers should review all declarations of interests from staff that they manage.  All declared actual, potential or perceived conflicts of interests should be reviewed considered by the Head of Division or Department or Committee Chair (as appropriate).  Further information can be found in section 8 and 9 of the Conflicts of Interest Policy.

What do I do if my circumstances change during the course of the year, and I have something new to declare?

You can update your annual declaration in MyView at any point during the year.

Why do I need to declare details of personal relationships within the School?

The School understands that personal relationships with fellow colleagues often develop over time and that in the majority of cases, these are positive. However, where there is also a professional relationship in which one member has, or may have influence, over another, it is important that both staff and students are protected from the potential of possible conflicts of interest – either perceived or actual.  More details can be found in the Personal Relationships Policy and Procedure.

How will my data be stored and who will have access to it?

We take data security very seriously. The School complies with Data Protection legislation (GDPR). Survey responses are stored securely. Data is used to respond to specific queries such as requests by the School’s auditors. Your managers will have access to this information via MyView.

How will my data be used?

Information from the declarations will only be used for the purposes of ensuring compliance with the School’s legal, regulatory and ethical frameworks and to manage any conflicts of interest. For example, if a member of staff activated the School’s ‘whistleblowing’ procedures to report alleged fraud involving a third party supplier, a search might be performed against the company name. Similarly, a change in world events might cause the School to examine the totality of its activities in a particular country or region; or allegations of corruption might prompt the School to examine links with a particular organisation or individual.

Will my data be made available to third parties?

Generally speaking, personal information provided in the survey cannot be made publicly available without the consent of the individual concerned. In a limited number of cases the School may be required to share data with regulatory or investigatory authorities. Data may be requested by third parties under the Freedom of Information Act 2001, but the Act provides considerable protection for individuals. Section 40 of the Freedom of Information Act 2001 contains a number of exemptions regarding the release of personal data, the most relevant of which is ‘fairness’ i.e. would it be fair to the individual in question if the data requested relating to them was released into the public domain.

 The interests of members of Council as both company directors and charity trustees are, as they have always been, open to public scrutiny. A summary of declarations from Council and Committee members will be published on the website.

In the unlikely event of a third party seeking information about your survey entry, the School’s Information and Records Manager would carefully examine the circumstances of the case against the ‘fairness’ test, following which it would be reviewed by the School Secretary. If you require further information, please contact the Records and Information Management Team, Tel: 020 7955 6481, Email: glpd.Info.Rights@lse.ac.uk.

I’ve read this guidance but still have questions. Who can I contact?

If you have any further queries, please email ethics@lse.ac.uk. 

Staff should declare any other relevant interests as they arise by notifying the Ethics Manager. 

• Conflicts of Interest Policy (PDF)
• Declarations of Interest Guidance (PDF)
• Guidance for managers on how to review staff declarations (PDF)
• Personal Relationships at Work Policy and Procedure (PDF)
• MyView Guidance on Declarations of Interest (PDF)
• Guidance for IGC: Declarations of Interests FAQ (PDF)
• For help with MyView, please visit our MyView webpage or contact hr.myview@lse.ac.uk 
• For help with your Declaration of Interests email ethics@lse.ac.uk.