Register of External Interests and Annual Declaration
The College's Register of External Interests and Annual Declaration Policy applies to all staff. It sets out College employees' obligations to complete the College's Annual Declaration of Interests return, and to seek approval before undertaking private engagements.
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Related policies which you may wish to refer to
- Conflict of Interests Policy - link to Central Secretariat
- Ordinance A5 - link to Central Secretariat
- Ordinance C1 (Financial Matters Part 8) - link to Central Secretariat
- Purchasing Regulation PR7 - link to Purchasing
- Gifts and Hospitality Policy - link to Central Secretariat
- Personal/Familial Relationships policy
- Post award management policy
- Ethics code [pdf]
Policy on relationships between Wellcome Trust-funded researchers and commercial organisations
The Wellcome Trust is a charitable trust that provides support for high-quality biomedical research. Through the various forms of support it awards, it seeks to foster both basic and applied research. The Trust wishes to ensure that the useful results of this research are applied for the public benefit (i.e. the research should give adequate public benefit, with only incidental private benefit). The Trust recognizes the importance of protecting and exploiting intellectual property arising from research as a means of achieving this public benefit. Accordingly, the Trust views it as desirable to encourage, where appropriate, scientifically productive relationships between Trust-funded researchers and commercial organizations. At the same time, it wishes to ensure that the intellectual integrity of Trust-funded researchers and their freedom to carry out curiosity-driven research are not compromised by such relationships.
Policy of the Trust
Consultancies and directorships
1. Trust-funded researchers may serve as consultants to commercial organizations. Consultancy is limited to the provision of advice and the exchange of ideas and must not include research or supervision of research. Consultancy must not enable a commercial organization to gain access to unpublished data, findings or conclusions from Trust-funded research that would give an unfair advantage to that organization over its competitors in access to Trust-funded research.
2. Trust-funded researchers may serve as non-executive directors of commercial organizations but may not serve as executive directors, except in exceptional circumstances. A Trust-funded researcher wishing to accept an executive directorship would have to relinquish all forms of ongoing Trust support, or would have to obtain the Trust's permission in writing for the Trust-funded research to continue with appropriate safeguards to ensure that the research would be brought to a satisfactory conclusion.
3. Researchers in receipt of salary support from the Trust must ensure that their time commitments to commercial organizations and other non-research activities are compatible with the policies of the institution and any conditions in the Award Letter.
4. The terms of each consultancy or directorship must be set out in a written agreement between the Trustfunded researcher and the commercial organization. Before entering into a proposed consultancy or directorship, the researcher must inform the institution. The institution is required to review in advance all proposed consultancy or director’s service agreements involving Trust-funded researchers and to ensure that the agreements are consistent with the policies of the institution, this policy and paragraph 7 of the Grant Conditions (‘Intellectual property and commercial activities’).
5. Where Trust-funded researchers are to be involved in commercial organizations, the arrangements for any transfer of intellectual property arising from the Trust-funded research must be in accordance with paragraph 7 of the Grant Conditions and the policies of the institution.
Disclosure and management of conflicts of interest
6. Trust-funded researchers holding consultancies in, or directorships of, commercial organizations are required to make a declaration of interests to their institution. Should no mechanism be in place to do so, the Trust funded researcher should notify the Trust.
7. The compensation of Trust-funded researchers for the work they undertake for commercial organizations may include fixed amounts of cash or equity (or both). Founding scientists may also receive fixed amounts of cash or equity (or both) in consideration of the transfer of intellectual property to a commercial organization, subject to compliance with paragraph 7 of the Grant Conditions and the policies of the institution.
8. Trust-funded researchers must disclose to their institutions (a) benefits in cash in excess of £10,000 per annum or (b) benefits in equity of any level, received either as compensation for work undertaken for a commercial organization, or in consideration of the transfer of intellectual property.
9. Trust-funded researchers holding equity in a commercial organization must make a declaration of interests to their institutions if they, together with members of their immediate family, hold, control or manage, directly or indirectly, (a) any level of equity in an unlisted company, or (b) equity in a listed company in excess of 1% of that company's equity interest. ‘Immediate family’ includes spouse or partner; minor children; and adult children (but only in so far as the Trust-funded researcher has knowledge of the interests of the adult children).
10. Trust-funded researchers must notify their institution in the event of any substantial upward or downward revision in the level of compensation received or the percentage or value of their equity interests, such as changes resulting from a professional financing round or the listing of the equity of the commercial organization.
11. The institution may require, at its discretion, that lower levels of cash or equity holdings (or both) should be disclosed.
12. Applicants for Trust funding will be required to indicate within the grant application form whether they have any consultancies or equity holdings in, or directorships of, commercial organizations that might have an interest in the results of the proposed research. Should they be successful in their application, confirmation may be sought that they comply with the policies of their institution or any Trust requirements (including this policy, the Grant Conditions and the Award Letter).
Responsibility for managing conflicts of interest
13. The Trust does not directly employ researchers, but funds them through their institution. Therefore, the institution is required to manage any conflicts of interest arising from disclosures made to it by Trust-funded researchers because of their involvement with commercial organizations.
14. In managing a perceived or actual conflict of interest, the institution must use all reasonable endeavours to ensure that the Trust is not put at risk of being in breach of charity law or regulation because of the relationship of a Trust-funded researcher with a commercial organization. In particular, the institution should act to ensure that the useful results of Trust-funded research are applied for the public benefit, with only incidental private benefit. This might involve requiring a Trust-funded researcher to relinquish direct control over some, or all, of the assets they hold in a commercial organization or requiring the level of compensation offered to the Trust-funded researcher to be capped.
15. Where (a) the policies of an institution that is applying for, or is in receipt of, Trust funds are not compatible with those of the Trust, (b) the institution does not have adequate monitoring procedures, or (c) the institution is unable to implement its procedures for whatever reason, the institution is required to inform the Trust. The Trust reserves the right to decide not to proceed with an application or to terminate an award where an institution is unable to comply with any Trust requirements (including this policy, the Grant Conditions and the Award Letter).
16. Where the institution has a concern about the commercial relationships of a Trust-funded researcher, it should seek to rectify that concern. At its discretion, the institution may approach the Trust for advice.
17. In cases where there has been a breach o f the policies of either the institution or the Trust, the Trust should be informed as soon as possible about the issues identified and the actions taken.
18. The Trust reserves the right at any time to require institutions or individuals who hold, or are seeking, Trust funds to provide to the Trust current information about consultancies, directorships and equity holdings covered by this policy, copies of all relevant documentation, copies of the institution’s policies and details of the institution’s monitoring procedures.
19. The Trust reserves the right to review the decisions taken by an institution in managing conflicts of interest of Trust-funded researchers in order to judge whether those decisions could have an adverse effect on the Trust’s compliance with charity law or regulation or the Trust’s activities or interests.
20. To the extent permissible by law or regulation, all information provided to the Trust in order to comply with this policy is treated as confidential.
‘Trust-funded researchers’ means all researchers benefiting from funds in any form from the Trust in order to advance their research.
‘consultancy’ means any compensated service for or on behalf of a commercial organization, including membership of a scientific advisory board or service as an expert witness, but does not include work undertaken for a publisher of academic journals or textbooks as an expert reviewer or author.
‘intellectual property’ is defined in the Grant Conditions.
‘equity’ means shares, share options, warrants, convertible debt or any other contractual or other right to acquire shares or options as an owner, proprietor, partner or beneficiary, or a beneficial interest in any of the foregoing.