EPSRC policy on conflicts of interest
Conflicts of interest occur where an individual involved in some way with the assessment of a proposal has a personal or organisational relationship with the applicants that call into question their ability to undertake their role in an objective and unbiased way. EPSRC has a long established policy that such conflicts should be identified and avoided within our peer review process, which is explicitly covered by the UKRI Impartiality Principle of Assessment and Decision Making. This policy statement sets out clear expectations of when conflicts of interest need to be declared and how they should be managed.
What constitutes a conflict of interest?
A conflict of interest can occur where there is any form of relationship between an applicant and somebody involved in any aspect of reviewing their proposal. As such it is difficult to provide a definitive and exclusive definition. The following are examples of some of the more common ways in which someone involved with the peer review of a proposal would have a clear conflict of interest:
- A named investigator or collaborator on the proposal
- Formal affiliation to any organisation involved in the proposal
- An existing business or professional relationship with any individual named on the proposal
- Close relative (including by marriage) of any individual named on the proposal
- Close personal relationship with any individual named on the proposal
- Professional link – for example where a recently supervised student or postdoctoral research assistant is an investigator or named researcher on the proposal
EPSRC will endeavour to avoid conflicts that can be identified from its own data records but many will not be identifiable in this way. The final responsibility for identifying and reporting conflicts of interest must therefore rest with the individual. Some cases will be clear cut but others will be less so and will require a judgement call. The clear test should be 'will a neutral observer have confidence in the impartiality of any advice provided' and in any case where there is significant doubt the relationship should be treated as a conflict.
Conflicts can arise at any stage within the peer review process and specific arrangements have been developed for managing these at each stage.
All reviews should be independent and objective. EPSRC will seek to avoid selecting reviewers where a conflict of interest is identified. This will include anyone with an identified personal or organisational association with the project to be assessed, and anyone with an identified personal association with any other proposal in direct competition for funding. Anyone asked to provide a review should check to ensure that there is no reason why they should not do so, and should decline the request citing 'conflict of interest' as their reason if they feel there to be a concern. Where a conflict is identified after a review is submitted that review will be classed as unusable and excluded from the process.
Panel guidance should reference this EPSRC conflicts policy and emphasise the need that panel members identify any conflicts of interest as early as possible in advance of the meeting. Where a conflict of interest is identified this will be recorded. Panel members meeting papers will be edited to remove relevant information regarding the conflicted proposal and the member will be asked to leave the meeting when it is discussed.
There is a particular conflict of interest between the roles of reviewer and introducing panel member for a proposal. For this reason EPSRC will avoid appointing anyone who has provided a review on a proposal to then sit on the panel assessing that proposal. Exceptionally this situation may be necessary in which case the panel member will be treated as having a clear conflict of interest with the proposal(s) in question, should leave the meeting in the normal way while it is discussed and should under no circumstances be permitted to speak to the proposal or comment on the other reviews provided on it.
EPSRC will not appoint anyone to serve on a prioritisation panel where they are a named investigator or collaborator on any proposal to be considered by that panel.
A clear record will be kept of all instances where a conflict of interest was identified and managed at a panel, and this information be included on the rank order list prepared showing the final panel recommendations.
For some smaller panels, particularly where these are interview panels, the standard practice of members leaving the meeting for a conflicted proposal may not be practical. In such cases no-one should be appointed to the panel where a conflict of interest has been identified. Should such a conflict be identified after the panel is appointed the member concerned will be asked to stand down and a replacement appointed, even if this requires that the meeting is postponed while this action is taken. To help minimise the risk to such panels of late recognition of conflicts, EPSRC will notify interviewees in advance of the membership of the panel so that they can identify if they believe a conflict exists.
EPSRC staff may also have connections with applicants that constitute a conflict of interest. Although their opportunity to influence outcomes is in practice limited, it is important that any such connection is identified to ensure impartiality of assessment. Under such circumstances staff should not be involved in reviewer selection or any decision stage for proposals where such a conflict can be recognised.