Conflicts of Interest

Conflicts of Interest explains how the Commons identifies, declares, records, manages, reviews, and resolves actual, potential, and perceived conflicts of interest.

A conflict of interest does not necessarily mean that someone has acted improperly. It means that an interest, relationship, commitment, role, or benefit could affect—or could reasonably appear to affect—the fairness, independence, integrity, or public credibility of a Commons decision or activity.

Purpose and Scope

The Commons depends on trust.

Members, participants, researchers, authors, editors, reviewers, partners, funders, providers, institutions, communities, and the public should be able to trust that Commons decisions are made fairly, independently, responsibly, and in accordance with the Commons’ purpose, Principles, Values, and governance arrangements.

Conflicts of interest can arise in ordinary professional, institutional, financial, personal, research, editorial, community, and collaborative life.

They may arise because a person holds more than one role, has an existing relationship with a person or organization involved, has received funding or support, may benefit from an outcome, has prior involvement in a matter, or holds a commitment that could reasonably affect impartial judgment.

The purpose of this framework is not to prevent collaboration, experience, expertise, community participation, institutional relationships, funding, professional activity, or lived-experience contribution.

Its purpose is to ensure that relevant interests are identified early, disclosed honestly, assessed fairly, managed proportionately, and recorded appropriately.

This framework applies to all Commons activity, including:

• Governance and decision-making
• Individual Membership and Institutional Membership
• Community Groups and Working Spaces
• Events and Learning
• Calls and Opportunities
• Research, Commission Requests, Concept Notes, Commissioning Briefs, and commissioned work
• Provider selection and procurement
• Journal Publication, editorial activity, peer review, authorship, and publication decisions
• Repository deposit, preservation, access, correction, restriction, withdrawal, and reuse decisions
• Partnerships and External Collaboration
• Funding, Sponsorship, donations, grants, gifts, in-kind support, and honoraria
• Safeguarding, participant protection, privacy, data, consent, and confidentiality decisions
• Complaints, review, appeal, conduct, access, suspension, and termination decisions
• Communications, public representation, advocacy, and external engagement
• Any other Commons decision, role, activity, arrangement, or relationship

All people acting for, with, or on behalf of the Commons should take reasonable steps to identify and disclose relevant interests.

What a conflict can look like

A conflict of interest may be actual, potential, or perceived.

Type	Meaning	Illustration
Actual conflict	A relevant interest is currently affecting, or may directly affect, a Commons decision or activity	A reviewer is asked to assess a proposal submitted by their employer or close collaborator
Potential conflict	A relevant interest could become a conflict in the future	A Working Space lead may later seek to provide paid services to a project they are helping to shape
Perceived conflict	A reasonable person could believe that an interest may affect impartiality, even if it does not	A funder’s representative participates in a discussion about publishing findings from work the funder supported
Institutional conflict	An organization’s interests, duties, relationships, or funding may affect a Commons role or decision	A university representative helps select a provider from their own institution
Financial conflict	A person or connected party may gain financially, directly or indirectly, from a decision	A person involved in a procurement decision owns shares in, consults for, or receives payment from a prospective provider
Personal conflict	A personal, family, household, close professional, or other relationship is relevant to the matter	An editor is asked to make a publication decision involving a close colleague or family member
Role conflict	A person holds responsibilities that should be separated to protect fairness or independence	The same person cannot fairly investigate a complaint, decide its outcome, and consider an appeal against that outcome
Research or editorial conflict	A relationship, commitment, belief, funding source, competing project, authorship interest, or prior involvement may affect research or publication judgment	A peer reviewer is reviewing a manuscript that challenges their own published work or competes with their current research

Relevant interests may include interests held by the individual, their employer, institution, close relative, household member, business, organization, collaborator, client, research team, or another connected person or body.

A conflict can arise whether or not money changes hands.

A conflict can also arise where a person expects no personal benefit but may wish to advance the interests, reputation, influence, visibility, ideology, institutional position, professional standing, publication record, research programme, network, or opportunities of a connected person or organization.

Interests that should be disclosed

People should disclose any interest that is relevant, or could reasonably be seen as relevant, to a Commons matter.

Relevant interests may include:

• Employment, office-holding, consultancy, board membership, trusteeship, advisory roles, or other professional duties
• Financial interests, investments, shareholdings, business ownership, royalties, licensing income, or anticipated financial benefit
• Grants, donations, sponsorship, funding, contracts, in-kind support, fellowships, scholarships, prizes, travel support, or honoraria
• Institutional affiliations, including university, research institute, charity, company, government, professional body, community organization, or other organizational relationships
• Current, recent, planned, or competing research activity
• Current, recent, planned, or competing publication, authorship, editorial, peer-review, Repository, or intellectual-property activity
• Partnerships, collaborative agreements, co-hosted work, co-commissioned work, supplier relationships, or provider arrangements
• Personal, family, household, intimate, friendship, supervisory, mentoring, adversarial, or close professional relationships
• Prior involvement in the issue, decision, complaint, review, investigation, publication, project, dispute, application, proposal, or activity under consideration
• Strong public statements, political commitments, advocacy activity, campaigns, legal action, public disputes, or other positions directly relevant to the matter
• Gifts, hospitality, travel, accommodation, services, discounts, invitations, or other benefits connected to Commons activity
• Any other interest that could reasonably affect, or appear to affect, independent judgment

The appropriate question is not only:

“Do I believe that I can remain impartial?”

It is also:

“Could a reasonable person, aware of the relevant facts, believe that this interest might affect my judgment, access, influence, or decision?”

If in doubt, disclose.

Early disclosure is normally the safest and most responsible course.

Disclosure and management

A person should declare a relevant interest as soon as they become aware of it.

Disclosure should occur:

• When accepting a Commons role
• When joining a committee, Community Group, Working Space, research project, editorial process, review panel, selection process, or other activity
• When submitting a proposal, Commission Request, Concept Note, manuscript, Repository deposit, funding application, Partnership proposal, provider proposal, or other material for consideration
• Before participating in a relevant discussion, meeting, review, assessment, vote, approval, selection, investigation, or decision
• When circumstances change
• When a new relationship, payment, funding arrangement, benefit, commitment, institutional role, publication interest, research interest, or other relevant interest arises
• When a person is unsure whether an interest is relevant

A conflict declaration should be made through the appropriate Commons route.

Depending on the activity, this may include:

• A role-acceptance declaration
• A meeting declaration
• A research or ethics declaration
• An editorial or peer-review declaration
• A provider or procurement declaration
• A Partnership declaration
• A funding or sponsorship declaration
• A Repository access or deposit declaration
• A complaint, review, or appeal declaration
• A safeguarding, privacy, data, or confidentiality declaration
• A Conflict-of-Interest Declaration Form
• Contact and Support

The Commons should assess the disclosed interest proportionately.

The assessment should consider:

• The nature and closeness of the interest
• Whether the interest is current, recent, anticipated, ongoing, or historical
• The significance of the decision or activity
• The person’s role, authority, access, influence, and relationship to the matter
• Whether the person may gain or lose financially, professionally, personally, institutionally, politically, or otherwise
• Whether affected people may reasonably question the fairness or independence of the process
• Whether confidentiality, privacy, safeguarding, research integrity, editorial independence, or another concern is involved
• Whether the interest can be managed safely and credibly
• Whether a different decision-maker, reviewer, adviser, editor, moderator, or route is needed

A conflict may be managed through one or more safeguards.

Possible safeguards include:

• Recording the interest in a relevant register or Decision Record
• Allowing participation in discussion but not in the final decision
• Requiring the person to leave the discussion for the relevant item
• Preventing the person from accessing certain information, records, applications, submissions, data, or communications
• Appointing an independent reviewer, editor, assessor, moderator, investigator, or decision maker
• Separating research, editorial, financial, governance, procurement, safeguarding, complaints, review, or appeal functions
• Requiring a second approval or enhanced oversight
• Restricting a person’s authority or role in the matter
• Changing the scope, timing, process, or reporting line of the activity
• Declining, pausing, suspending, withdrawing, or ending the activity, decision, role, arrangement, or relationship
• Referring the matter to the Commons Governance Authority or another appropriate authority

The response should be proportionate.

Not every conflict requires exclusion from all activity. Some interests can be managed through transparency and limited safeguards. Other interests may be so direct, material, sensitive, or significant that recusal, reassignment, independent review, or withdrawal is necessary.

Responsibilities

Everyone involved in Commons activity has a responsibility to support fair and independent decision-making.

Individuals

Individuals should:

• Read and follow this framework and any relevant Commons policy, procedure, agreement, role description, access condition, editorial standard, research standard, or participation requirement
• Consider whether they hold an actual, potential, or perceived conflict of interest
• Disclose relevant interests accurately, promptly, and in good faith
• Update a declaration when circumstances change
• Follow agreed safeguards, including recusal, confidentiality, restricted access, independent review, or reassignment
• Avoid using a Commons role, Membership, access route, Working Space, research process, editorial process, Partnership, funding arrangement, or personal relationship to obtain improper advantage
• Avoid exerting pressure on another person to overlook, minimize, conceal, or manage a conflict inadequately
• Seek guidance where uncertain
• Raise a concern if they believe that an interest has not been declared or is not being managed appropriately

Role holders and decision makers

People with governance, administrative, research, editorial, financial, safeguarding, data, Membership, Partnership, provider-selection, Repository, Community Group, Working Space, or other decision-making responsibilities should:

• Request relevant declarations before making a significant decision
• Ensure declarations are considered before discussion, assessment, review, approval, selection, or vote
• Record relevant interests and management arrangements appropriately
• Ensure that a person with a conflict does not exercise inappropriate access, influence, authority, or decision-making power
• Seek independent or specialist input where needed
• Escalate material, complex, unresolved, sensitive, or high-risk conflicts
• Treat disclosed information with appropriate privacy and confidentiality
• Review management arrangements if the matter changes or new information emerges

Commons Governance Authority

The Commons Governance Authority should ensure that appropriate conflict-of-interest arrangements exist across the Commons.

This includes maintaining or overseeing:

• A Conflict-of-Interest Policy and declaration process
• A proportionate Conflict-of-Interest Register
• Clear decision-making, delegation, recusal, review, and appeal arrangements
• Independent routes for research, editorial, complaints, safeguarding, privacy, data, financial, provider-selection, Partnership, funding, and governance matters where needed
• Appropriate separation of incompatible functions
• A process for reporting, investigating, reviewing, and resolving concerns
• Regular review of governance arrangements, significant conflicts, recurring issues, and lessons learned

Research and publication

Research integrity and editorial independence are essential to the Commons.

A person involved in research, commissioning, provider selection, ethics review, data management, peer review, authorship, editing, publication, Repository activity, correction, retraction, or research-related decision-making should disclose relevant interests early.

Research and editorial conflicts may include:

• A financial or institutional interest in a research outcome
• Funding from a party with a material interest in the research, publication, policy, service, product, intervention, or finding
• A close collaboration, supervisory relationship, employment relationship, or personal relationship with an author, contributor, provider, participant, editor, reviewer, or project lead
• Competing research, publication, grant, intellectual-property, commercial, academic, or professional interests
• A role in commissioning, conducting, reviewing, editing, funding, promoting, or implementing the work under consideration
• Prior involvement in a dispute, complaint, correction, retraction, appeal, or review relating to the work
• A strong public position that may affect, or may appear to affect, assessment of the evidence or manuscript
• A relationship with a funder, sponsor, provider, partner, institution, government body, campaign organization, company, professional body, or other interested party

The Commons should protect the independence of research and publication decisions.

Funders, sponsors, partners, employers, institutions, Members, providers, donors, and other external parties should not determine research findings, suppress valid findings, direct editorial conclusions, select favourable reviewers, prevent legitimate correction, or use financial or institutional influence to obtain favourable treatment.

Funding, support, contributions, affiliations, acknowledgements, competing interests, and relevant limitations should be disclosed in an appropriate form.

Disclosure alone may not always be sufficient.

Where a conflict is material, the Commons may require independent review, an alternative editor or reviewer, a different decision maker, enhanced transparency, independent oversight, reassignment, restricted access, or another safeguard.

Funding, partnerships, and providers

The Commons may work with funders, sponsors, donors, institutions, partners, providers, collaborators, and supporters.

Such relationships can support valuable public-interest activity. They can also create real or perceived risks to independence, fairness, procurement, research integrity, editorial integrity, community trust, and public confidence.

The Commons should assess relevant interests before entering, renewing, varying, or closing a significant funding, sponsorship, Partnership, provider, or external collaboration arrangement.

Particular care should be taken where an external party may seek to influence:

• Commons governance or strategic direction
• Membership decisions or access decisions
• Community Group or Working Space activity
• Research topics, methods, providers, findings, interpretation, dissemination, or publication
• Editorial selection, peer review, publication, correction, retraction, or Repository access
• Provider selection, procurement, payment, contract renewal, or project evaluation
• Public communications, advocacy, representation, or reputational positioning
• The treatment of a complaint, safeguarding concern, privacy matter, data request, conduct concern, or review process
• Decisions affecting competitors, critics, collaborators, communities, participants, institutions, or other parties

Funding, sponsorship, support, and Partnership arrangements should be governed by appropriate documentation.

Where relevant, this documentation should make clear:

• The purpose of the arrangement
• The resources, responsibilities, deliverables, conditions, and duration
• Any approved public acknowledgement or attribution
• Data, privacy, confidentiality, consent, intellectual-property, Repository, licensing, publication, and preservation arrangements
• Research-integrity and editorial-independence protections
• Conflict-of-interest declarations and management arrangements
• Financial controls, reporting, audit, and payment arrangements
• Safeguarding, participant-protection, accessibility, inclusion, and community-participation arrangements
• Review, suspension, termination, and closure arrangements
• The limits of the external party’s authority and influence

No funding, sponsorship, Partnership, donation, or other support arrangement should override the Commons’ purpose, Principles, Values, governance responsibilities, research integrity, editorial independence, safeguarding duties, privacy commitments, data responsibilities, or public-interest obligations.

Gifts, hospitality, and benefits

People acting for or with the Commons should not request, accept, offer, or provide gifts, hospitality, travel, accommodation, services, discounts, invitations, payment, or another benefit where it could improperly influence a Commons decision or could reasonably be seen as doing so.

Modest, customary, proportionate, and transparent hospitality may sometimes be appropriate.

However, gifts, hospitality, benefits, or invitations should be declined, disclosed, returned, recorded, or otherwise managed where they are:

• Excessive, frequent, private, conditional, or inappropriate
• Offered during a live procurement, funding, editorial, research, Partnership, recruitment, appointment, review, complaint, or decision process
• Connected to a request for favourable treatment, access, influence, endorsement, publication, selection, payment, appointment, or another benefit
• Likely to compromise, or appear to compromise, independent judgment
• Inconsistent with applicable law, policy, contractual obligations, professional standards, institutional requirements, or Commons Values

The Commons should maintain a Gifts, Hospitality, and Benefits Register where appropriate.

Records and Confidentiality

The Commons should keep proportionate records of relevant declarations, assessments, management arrangements, recusals, decisions, reviews, and outcomes.

A Conflict-of-Interest Record may include:

• The person’s name, role, and relationship to the Commons
• The activity, decision, project, manuscript, proposal, funding arrangement, Partnership, Working Space, provider process, complaint, review, or other matter concerned
• The declared interest
• The date of disclosure
• The person or body assessing the conflict
• The management steps agreed
• Any recusal, restriction, independent review, reassignment, or other safeguard
• The date for review, if applicable
• The final outcome or closure decision

Conflict-of-interest information should be handled carefully.

The Commons should disclose enough information to support accountability, trust, and fair process while protecting privacy, confidentiality, safeguarding, personal data, sensitive commercial information, research confidentiality, editorial confidentiality, legal obligations, and the rights of others.

Some declarations may be published, summarized, or referenced in public records where this is appropriate.

Other information may be retained confidentially because wider disclosure would be disproportionate, unsafe, unnecessary, or inconsistent with applicable obligations.

Concerns and Non-Disclosure

Anyone may raise a concern if they believe that:

• A relevant interest has not been declared
• A conflict has been inadequately assessed or managed
• A person has participated improperly in a decision
• A funder, sponsor, donor, partner, institution, provider, Member, or other party has sought improper influence
• Research, publication, peer review, Repository activity, provider selection, funding, Membership, Partnership, safeguarding, privacy, data, or another Commons process may have been compromised
• A person has faced retaliation, exclusion, disadvantage, pressure, or intimidation for declaring a conflict or raising a concern
• A Conflict-of-Interest Record may be inaccurate, incomplete, outdated, or improperly disclosed
• A decision should be reviewed because a previously unknown conflict has emerged

Concerns should be raised through Contact and Support or through the appropriate complaints, safeguarding, privacy, research-integrity, editorial-integrity, financial, governance, or review route.

The Commons should handle concerns fairly, proportionately, confidentially where appropriate, and with appropriate independence.

A person should not be penalized merely for declaring a conflict of interest in good faith.

However, failure to disclose a material conflict, failure to follow agreed safeguards, misuse of a Commons role, improper influence, concealment, retaliation, or deliberate misrepresentation may lead to review, restricted access, reassignment, suspension, termination, referral, or another proportionate action.

Operational Documents

The Commons should maintain the following supporting documents and tools.

Conflict-of-Interest Policy

This should define the Commons’ approach to actual, potential, and perceived conflicts; disclosure; assessment; recusal; management; records; review; complaints; and consequences of non-disclosure.

Conflict-of-Interest Declaration Form

This should allow people to declare relevant financial, institutional, professional, personal, research, editorial, Partnership, funding, provider, political, intellectual-property, and other interests.

Conflict-of-Interest Register

This should record relevant declared interests, management arrangements, review dates, recusals, decisions, and closures in a proportionate and appropriately confidential form.

Meeting Declaration and Recusal Record

This should record declarations made before or during a meeting, any relevant discussion restrictions, withdrawals, recusals, independent review arrangements, and the final decision route.

Research and Editorial Competing-Interest Form

This should support declarations by authors, researchers, research providers, editors, editorial advisers, peer reviewers, data stewards, Repository contributors, and other research or publication participants.

Funding, Partnership, and Provider Declaration Form

This should support disclosure and management of interests arising from grants, sponsorship, donations, procurement, provider selection, institutional arrangements, external collaboration, and other support or commercial relationships.

Gifts, Hospitality, and Benefits Register

This should record gifts, invitations, travel, accommodation, discounts, services, hospitality, honoraria, and other benefits where a record is required.

Conflict Review and Escalation Procedure

This should explain how material, unresolved, sensitive, high-risk, disputed, or alleged undeclared conflicts are assessed, escalated, independently reviewed, managed, varied, suspended, or closed.

Contact and support

Use Contact and Support if you need guidance about a possible conflict of interest, declaration, recusal, funding relationship, Partnership, provider selection process, research activity, publication matter, Repository decision, gift, benefit, or another related concern.

You may use this route to:

• Ask whether an interest should be declared
• Request a Conflict-of-Interest Declaration Form
• Seek guidance before accepting a Commons role or participating in a decision
• Update an existing declaration
• Ask how a conflict will be managed
• Raise a concern about possible non-disclosure or improper influence
• Request information about a relevant policy, procedure, record, review route, or decision
• Seek support if you are concerned about retaliation or unfair treatment after making a declaration or raising a concern

Essentially the Commons ensures that Conflicts of interest are enforced by ensuring that:

• People understand that disclosure is a normal part of responsible participation, not an accusation of wrongdoing
• Relevant interests are disclosed early and updated when circumstances change
• The Commons distinguishes between actual, potential, and perceived conflicts
• Decisions are made fairly, independently, and within clear authority
• Material conflicts are recorded and managed proportionately
• People with relevant interests do not exercise inappropriate access, influence, or decision-making authority
• Research integrity, peer-review integrity, editorial independence, Repository integrity, and accurate reporting are protected
• Funders, sponsors, donors, partners, providers, institutions, Members, and other external parties do not gain improper influence
• Community participation, lived experience, professional knowledge, institutional expertise, and collaboration are welcomed without compromising fairness or independence
• Safeguarding, privacy, data, confidentiality, accessibility, inclusion, and participant welfare are considered in conflict management
• People can raise concerns safely and without retaliation
• Significant decisions can be understood, reviewed, and accounted for appropriately
• The Commons remains credible, independent, fair, transparent, and worthy of public trust

Safeguarding and Participant Protection explains how the Commons protects the welfare, dignity, safety, rights, and interests of children, adults at risk, research participants, contributors, volunteers, Members, and others involved in Commons activity.