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Conflict of Interest
Frequently Asked Questions (FAQ)
General
1. Must I make a Conflict of Interest declaration?
ANSWER:
The Conflict of Interest Policy applies to:
- All students
- All full-time staff, including those on part-time work arrangement, leave for academic purposes (e.g. sabbatical leave), no-pay leave or any other type of leave
- Part-time staff e.g. adjunct staff
- Full-time and part-time visiting staff
- Staff appointed under the Part-time Teaching Appointments Scheme
- Casual staff
Please refer to the FAQs (https://ormc.nus.edu.sg/compliance/conflict-of-interest/faq) for examples of situations which you should declare.
During the annual COI declaration exercise, all Full-time staff are required to make a ‘Nothing to Declare’ submission even if they do not have any conflict.
2. I cannot change my answer to a question in my COI declaration form. How do I solve this problem?
ANSWER: Please ensure that you are on the editing page, not the preview page, for the declaration form. If you are on the preview page, click “Back” at the bottom of the screen to return to the editing page.
If the issue persists at the editing page, you will have to delete the draft declaration and submit a new one by doing the following:
- Open up the draft declaration
- Scroll to the bottom and delete the draft
- Submit a new declaration
3. I cannot access the COI declaration website. How can I solve this issue?
ANSWER:
Please log into the VPN first and ensure that you have the right link (https://aces.nus.edu.sg/coi/home) for the COI system.
Should you have trouble connecting to VPN, please contact NUS IT Care at 65162080.
4. I am the Department liaison with a vendor providing a service to my Department. The vendor has invited me to its annual company trip overseas for its staff and associates of the company. Should I accept? I do not wish to offend the vendor by rejecting the invitation.
ANSWER: No, you should not accept the invitation and you should make a declaration.
REASON: You should declare this invitation to the University because as a general rule, staff should not accept any gifts(or meals) from any third party, as acceptance of such gifts (or meals) can be perceived as an attempt to influence staff in favour of the third party.
5. I helped out a student who suffered a bad fall on campus and needed to be taken to hospital. Her grateful parents passed me a gift of a diamond ring through my office receptionist. Do I need to declare this gift to the University?
ANSWER: Yes.
REASON: A staff member should not accept any direct or indirect gifts from an external party or a student in his or her capacity as a University employee or NUS’ representative. If circumstances are such that it is impractical to refuse a gift or it would be discourteous to return the gift, a staff member should report the circumstances and details of the gift to the Head/Dean. If Head/Dean is the recipient, then it should be reported to his or her next level of approving authority.
6. Can I procure consultancy or other services from someone that I know?
ANSWER:
Subject to prevailing University Procurement Policy, you may only obtain consultancy services from someone that you know by justifying that the person has the relevant skills/experiences. To avoid a potential conflict of interest, you will be required to recuse yourself from any involvement in the procurement and payment relating to this service.
For example, if the potential consultant and you have a prior/current personal or business relationship, you must declare the potential conflict of interest and recuse yourself from the procurement and payment of the service rendered.
Student Admissions
1. My daughter will be an NUS student in the coming academic year but she will not be enrolled in the same Faculty that I am working in. Do I need to inform the University?
ANSWER: Yes.
REASON: Even though your daughter will not be enrolled in the same Faculty that you are working in, you should declare your family relationship for the necessary due diligence to be made on whether you have access to some of the Academic Related Systems or if you could be involved in some stages of the Assessment Processes. COI Team will assess if there is any potential conflict of interest.
2. I am currently a Research Assistant at Faculty of Science. I just found out recently that my nephew who went for NS had ORD-ed and is going to enter NUS this coming Academic Year. Do I need to do a COI declaration?
ANSWER: Yes.
REASON: Since your nephew is entering NUS, even if he will not be entering the same faculty as you, you should declare your family relationship for the necessary due diligence to be made on whether you could be involved in some of the modules taken by your nephew during his academic semester. COI Team will assess if there is any potential conflict of interest.
Student Relations
1. I am the Teaching Assistant for the module that my brother is taking right now and will be grading his work. Do I have to inform the University (even if I wouldn’t be in a position to give him any advantage)?
ANSWER: Yes.
REASON: Since your brother is taking a module under you, you will have to ensure that the lecturer/professor and your RO is aware of this relationship and that sufficient steps are taken to prevent any conflict of interests, e.g. handling only the tutorial sessions where your brother is not assigned to or in the worst case, abstain from teaching the module this academic semester. COI Team will assess if the steps taken are sufficient to avoid a potential conflict of interest.
2. My niece is studying in the same faculty where I am working as a Research Assistant. However, I have no access to the Academic-related systems and cannot see or edit any of her information. Do I have to make a COI declaration?
ANSWER: Yes.
REASON: Since your niece is in the same faculty as you, you will have to ensure that the professor and your RO is aware of this relationship. COI Team will assess if there is any potential conflict of interest.
Staff Relations
1. I am currently a NUS staff member, and my wife has just joined another department of the University. In my work, I will likely have to connect with my wife in relation to procurement matters. She has declared to the University that she is married to a NUS staff. Do I need to declare separately?
ANSWER: Yes.
REASON: You should make a separate declaration that your wife is an NUS staff member and the areas of work that will require working with your wife.
2. My girlfriend/fiancee was recently employed by NUS in a different faculty. Do I have to inform the University?
ANSWER: Yes.
REASON: Even though the staff is not officially your spouse, there may be areas of work between you and your significant other that may result in conflict of interest. The COI Team will assess if there is any potential conflict of interest.
3. I work in the NUS admin cluster and my father-in-law owns a company called YOG. Do I need to declare what my father-in-law does?
ANSWER: With respect to your query, please assess if the financial interest(s) of your parents/spouse/siblings in the 3rd party organisation poses a potential conflict with your employment at NUS and declare further details under Question 7. If you happen to have any directorships in your father-in-law’s company without approval sought through NED, please declare under Question 4.
External Commitments
1. I am a Non-executive Director of a recreational club/religious facility. Any work in relation to the NED will be carried out after work hours or on weekends. I will not be remunerated for the appointment. Do I need to declare this directorship?
ANSWER: Yes.
REASON: The Rules on acceptance of non-executive directorships and executive directorships/managerial positions require you to declare and seek approval for Non-executive Directorships before taking up such roles regardless whether you have received any remuneration or played an active role to-date.
2. I have contributed funds to my sister’s clinic so she has made me a Director. I am not involved in any way with the clinic. Do I need to declare the Directorship to the University?
ANSWER: Yes.
REASON: Approval needs to be sought from the University for all directorships. If the directorships are executive directorships, you should note that full-time staff are prohibited from holding partnership given the executive/managerial nature of such roles.
3. I have received approval from the University to carry out consultation work for a company. However, I now do not have time to do the job. I have a colleague in the University who is willing to do the job. I intend to give him 3/4 of the remuneration to be received and keep the rest of the monies. The job will still be under my name. May I do so?
ANSWER: No.
REASON: You may not do so as the approval for the job has been given to you and not your colleague. You are also not allowed to subcontract a consultancy under your name.
4. I am currently on no-pay leave. I wish to set up a business which is related to one of my hobbies and which I will carry out only after work hours. Am I allowed to do so?
ANSWER: No.
REASON: Full-time staff are prohibited from accepting executive/managerial positions (including executive directorship positions) in companies, partnerships or sole proprietorships. The prohibitions applies regardless whether a staff member is on no-pay leave or on sabbatical leave as he/she is still a full-time employee of the University.
5. I own a company and its business has nothing to do with the nature of my work in the University. Do I need to declare my ownership of this company?
ANSWER: Yes.
REASON: Full-time staff are prohibited from being a sole-proprietor given the executive/managerial nature of such a role and there is potential conflict of commitment of time and energy to the University. Please note that if you have an ownership or directorship without a position, it belongs in question 7 of the COI declaration. However, if you have a directorship but have yet to obtain approval through NED, you will have to declare it in question 4.
6. I have been approached by another NUS Department to do some consultation work for them which I will carry out after work hours. Do I need to seek approval from my Head of Department?
ANSWER: Yes.
REASON: Your eligibility to undertake consultation work is dependent on your staff category and level of appointment. Correspondingly, your approver(s) are determined by your staff category and level of appointment. In addition, you should note that unless specially approved by the University, a full-time staff may not receive payment beyond his/her regular salary for undertaking work which would not be viewed as part of the work which h/she would have been expected to carryout in the normal course of his/her duties, in his own department or for any other department within the university. Only after this special approval is obtained by the co-opting department may the staff seek approval from his/her approver(s) to carry out the work.
7. I was offered a part time graphics design work for a company. The work is unrelated to my NUS work and I am only required to work for the company after working hours. Will I need to make a declaration?
ANSWER: You would require approval for engagement in any employment, even if casual. Eligibility will depend on your staff category and level of appointment. The policy under Consultation Work Scheme will apply.
8. I am currently a staff in the University. I wish to give private tuition to secondary school students after work hours and on weekends. Do I need to declare this outside activity to the University?
ANSWER: Yes.
REASON: There is a potential conflict of interest as the proposed work does not complement and enhance your roles and responsibilities in the University. Consultation work should not be for the sole purpose of the faculty member earning additional income nor should such work adversely affect the academic independence of the faculty member to compromise the reputation and standing of the University. There is also a potential conflict of commitment of energy to the University as the time spent giving private tuition may result in inadequate rest such that you may be unable to perform your duties optimally for the University.
Please note that only the following categories of staff may undertake External Consultation Work:
- For Full-time academic staff on Tenure Track, Educator Track, Practice Track and under the Visiting Appointments Scheme of the grades of Lecturer, Senior Lecturer, Assistant Professor and above.
- Research staff and full-time Visiting Research Staff of all grades in Teaching Departments or University-level Research Institutes/ Research Centres, as well as all other academic staff of the grades of appointment below Lecturer, Senior Lecturer and Assistant Professor.
- E&A staff job level E3 and above,
9. I was approached by Company AA to give a talk on my area of expertise and it will be pro bono (will not be getting honorarium nor claiming reimbursement). It is something within my area of expertise and research. There is no conflict of interest in the material used, so I think there may not be any conflict of interest. Would I still need to declare?
ANSWER: Yes.
REASON: Prior to accepting the engagement, you should seek the approval of your Reporting Manager, and if obtained, a declaration of COI will not be required.
10. I was serving in an ex officio capacity on the board of a government stat board, due to my previous appointment as Dean. My appointment has since changed as my term has ended, but I still maintain my position in the government board, upon the board’s request. Do I have to declare the continued appointment on the board?
ANSWER: Yes.
REASON: Since your ex officio appointment has ended, your continued involvement on the board will be an external commitment that will require approval under the Consultation Work Scheme.
Intellectual Property
1. I have recently came up with a new invention using the University's resources. Do I have to make a declaration?
ANSWER: No.
REASON: Should you have any interest in commercializing your invention, please contact TTI first who will assist you.
2. I am planning to register an IP and I have already contacted the Technology Transfer and Innovation (TTI). Do I still need to make a declaration here?
ANSWER: No.
REASON: Since you have already communicated your intent to the TTI, there is no need to make a COI declaration.
Financial Interest
1. I am a sleeping partner in my friend’s company and am not even sure if it is active or dormant. Do I need to declare my role in this company to the University?
ANSWER: Yes.
REASON: Full-time staff are prohibited from accepting executive/managerial positions (including executive directorship positions) in companies, partnerships or sole proprietorships, given the potential conflict of one’s commitment of time and energy to the University.
2. My father’s company was successful in its bid for the provision of cleaning services to UCI. I belong to the History department of FASS in the academic cluster and have no relationship to the company. I am also not involved in the procurement or approval process and have no involvement with UCI. Do I need to declare this scenario to the University?
ANSWER: No.
REASON: There is no potential or apparent conflict of interest as you were not a part of the procurement process and your Department is not involved in the tender.
3. My husband owns a company that produces lab equipment and intends to respond to a tender called by a NUS Research
Institute to which I belong to. I am involved in the procurement process. Do I need to inform the University about the
relationship and exclude myself from the procurement process?
ANSWER: Yes.
REASON: You should declare full details of the potential conflict, and inform your Reporting Manager of the issue and exclude yourself from the procurement process in relation to this tender.
4. I am a PI of a research project which the University has a collaboration with another AU and the co-PI from that AU is my wife. Is there anything that I have to declare?
ANSWER: Yes.
REASON: You would need to make a declaration in view of the fact that your wife is receiving remuneration from the other AU (in the form of wages) and she is also involved in agreements and transactions between NUS and the AU she is working for. The COI Team will assess if there is any potential conflict of interest.
5. I am not a major shareholder of any company but have a modest share portfolio. Do I need to declare it to the University?
ANSWER: With respect to your query, please assess if your share portfolio organisation poses a potential conflict with your employment at NUS and declare further details under Question 6. If you happen to have any directorships your company without approval sought through NED, please declare under Question 4. If your shares are listed on the public stock exchange, no declaration is required.
6. I am a PI of a research project with a company which I am a founder and a shareholder of. However, I am not in a position of making any decision in that company and only hold an NED appointment. Do I have to inform the university or make any other arrangements?
ANSWER: Yes.
REASON: Firstly, you will have to declare and inform the University of your NED as per the Rules on acceptance of non-executive directorships and executive directorships/managerial positions regardless whether you have received any remuneration or played an active role to-date. You will also have to declare your own financial interest under question 6.1, stating the percentage of share you have in the company. A management plan on how to address the potential conflict of interest will be required, e.g. an independent party to observe all transactions conducted to ensure there is transparency in the research project.
Research
1. Do I Include or declare my performance bonuses as additional benefits received from my Research Project?
ANSWER: No.
REASON: Performance bonuses are not considered benefits above and over your salary.
2. I applied for a reimbursement for my air ticket trip to a conference overseas last month. Do I have to declare it as
additional benefits?
ANSWER: No.
REASON: When applying for reimbursement, it is necessary to obtain approval from your RO. Hence, there is no need to declare it in the COI declaration.