Examples of Conflicts of Interest

A sample of activities and situations that may present a Conflict of Interest are listed below as well as some sample management plans. In addition, examples specific to procurement, research, consultancy and involvement in a company and sample mitigation options are listed. Examples are for illustrative purposes only and are not exhaustive.

Individuals using their position of employment or engagement with Trinity to:

influence a contract to provide favourable terms for a company in which they, or a Connected Person, have a financial interest or any other personal interest;
accept gifts, gratuities or favours from a third party engaged in or wishing to engage in transactions with the University, except in the case of customary gifts of a nominal value¹;
influence employment, promotion, admission to a course of study, educational progression or other financial or non-financial benefit for a Connected Person;
obtain financial or non-financial benefits for themselves or for a Connected Person in return for providing advantage, or potential advantage to a person they are connected with;
use Trinity resources² or Trinity confidential information for personal financial or non-financial benefit, or benefit to a Connected Person;
conduct business or activity, inside or outside of Trinity, which adversely affects Trinity or any employee’s ability to perform their Trinity duties;
compromise research objectivity or independence in return for financial or non- financial benefit for them or for a Connected Person;
influence research grants or research activity;
provide Trinity resources below market rates;
provide favourable contractual terms to a Trinity Campus Company, Start-up or Spin-In to which they are connected.

It may also include having any close relationship (current or historical) with the supplier/contractor.

[1] Nominal value in this instance refers to gifts with a combined value of no more than €650 per annum as per the Ethics in Public Office Acts 1995 and 2001.

[2] This does not apply in situations where a researcher has founded a spin out and requires a facility agreement for the spin out to access Trinity resources.

See section 6.1 of the Policy for further details.

Management plans may include, but are not limited to, the following:

declaring the potential, actual or perceived conflict of interest but taking no further action;
enquiring as to whether all affected parties will consent to the conflicted person's involvement;
seeking a formal exemption to allow participation (if such a legal power applies);
imposing additional oversight or review over the person with the conflict;
refraining from examining, supervising or advocating on behalf of a student where a personal relationship exists;
withdrawing from discussing or voting on a particular item of business at a meeting;
absenting oneself from any meetings or discussions in relation to a student where a personal relationship exists;
exclusion from a committee or working group dealing with the issue;
re-assigning certain tasks or duties to another person;
agreement or direction not to do something;
withholding certain confidential information, or placing restrictions on access to information;
transferring the person (temporarily or permanently) to another position or project;
relinquishing the private interest;
temporarily suspending the conflicting activity until the matter has been resolved;
declining to enter into a contract with a third party;
replacing the conflicted individual with another to deal with the activity from which the conflict has arisen.

See section 6.3.2 of the Policy.

Example 1 – Connected Person

A member of the Trinity Community is asked to participate in the evaluation or negotiation of a new contract where they, a relative, a connected person, or a connected entity have a financial or non-financial interest in a bidding supplier (e.g. shareholding, directorship, consultancy arrangement).

Potential recommendation: The individual should declare the conflict of interest immediately and excuse themselves from all procurement-related activities, including evaluation, negotiation, and recommendations to the Procurement Office.

Example 2 – Prior Relationship with a Supplier
A member of the Trinity Community is asked to provide technical input into the evaluation of bids for a new contract and has previously worked for one of the bidding suppliers more than three years ago, with no ongoing financial interest.

Potential mitigation options:

The individual should declare the interest before participating.
Their role may be limited to providing factual or technical advice only, with no scoring or recommendation authority.
An independent reviewer should validate any technical input provided.

Example 1

Supervising a research project (student or postdoc etc) in which the supervisor has a financial interest in the results of the research.

Potential mitigation options:

The conflict of interest should be declared and a different supervisor should be appointed for the project. Results should be independently reviewed.

Example 2

Procuring equipment or services from a supplier in which the PI/staff member or someone they know has an interest.

Potential mitigation options:

The conflict should be declared and the staff member should not take part in any decisions related to procuring equipment or services from the supplier.

Example 3

An academic is an editor of a commercial journal but is also involved in university decision making related to journal subscriptions.

Potential mitigation options:

The academic should declare the conflict of interest and remove themselves from the decision-making process.

Example 1

A member of the Trinity community is due to take part in a consultancy between the University and a company where they have a financial or non-financial interest (e.g. a directorship) in that company.

Potential recommendation: The member of the Trinity community should excuse themselves from all negotiations with the company and ensure that relevant Trinity professional staff manage all negotiations (e.g. the consultancy agreement and consultancy rates)

Example 1

A member of the Trinity community is due to take part in a collaboration between the university and a company where they or connected person have a financial or non-financial interest (e.g. a directorship) in that company.

Example 2

A member of the Trinity community is the coordinator of a large project, and they have a financial or non-financial interest (e.g. a directorship) in a company that is a partner in the project.

Potential recommendation: The member of the Trinity community should declare their interest to all partners in the consortium. The member of the Trinity community should be replaced by another member of the consortium in relation to financial or performance considerations relating to the partner company.

Examples of Conflicts of Interest