Conflicts of interest policy: Wellcome-funded researchers and commercial organisations

Wellcome encourages engagement with others to increase the impact of research outputs. This could involve:

• providing consultancy services
• sitting on a technology advisory board
• acting as an officer of a company
• helping your organisation to license out intellectual property (IP)
• advising on relevant government policy.

Researchers and host organisations must identify and effectively manage any potential or actual conflicts of interest so that:

• the highest ethical standards of research integrity are maintained
• the delivery of Wellcome-funded research is not negatively impacted
• the outputs of the research are used to try to achieve the greatest possible public benefit by improving human health. Any private benefits (such as payments or equity flowing to researchers, their host organisations or to any commercial organisations) should be no more than incidental to the delivery of the desired public benefit.

A conflict of interest exists when an individual’s personal interests, those of their family, or their loyalties to another person or organisation, may (or may reasonably appear to) unduly influence or affect a decision.

For example, there would be a conflict of interest if a university considered licensing Wellcome-funded IP to a company in which a researcher owned shares. In this case the conflicted researcher should not exercise any influence over the university’s decision to offer the licence, or the terms on which it is offered.

Researchers must:

• ensure that commitments to other activities do not prejudice the timely delivery of Wellcome-funded research
• avoid any activities that jeopardise the ethical conduct of research and/or the potential use of Wellcome-funded research outputs to improve human health
• disclose to their organisation as soon as possible any actual or potential conflict of interest related to the conduct of Wellcome-funded research and/or the potential use of resulting research outputs.

In particular, in each case where a commercial entity has a potential interest in the Wellcome-funded research or in any directly related fields, researchers must inform their organisation and comply with their organisation’s requirements:

• before they act as a consultant or adviser to that commercial entity
• before they enter into any research collaboration, sponsorship or other funding agreement with that commercial entity
• before accepting any directorship at that commercial entity
• if the researcher, or any immediate family member, is employed by or owns shares in, that commercial entity.

The host organisation must:

• Have a formal policy to identify and manage potential conflicts of interest.
• Assess all potential conflicts of interest involving Wellcome-funded researchers, their research projects or outputs, to determine if the conflict is material and if so how it should be managed.
• Ensure that conflicts of interest and their management do not put Wellcome at risk of breaching charity law or regulation. In particular, you must ensure that relationships and transactions promote public benefit (with only incidental private benefits) and that the use of Wellcome-funded research outputs comply with our policy on data, software and materials management and sharing and our policy on intellectual property.
• Ensure that researcher relationships and activities that might create potential conflicts (such as consultancies, advisory roles, board memberships and material transfers) are set out in formal written agreements which protect Wellcome’s interests in the conduct of the research and the potential use of the outputs to improve human health.
• Ensure that agreements transferring ownership of, or licensing rights to, any Wellcome-funded IP (including granting access to unpublished data or conclusions) comply with the terms of any funding from Wellcome, such as paragraph 8 of the grant conditions and Wellcome’s policy on intellectual property. These agreements must be negotiated as arm’s length transactions, especially where Wellcome-funded IP is being assigned or licensed to a researcher or to a commercial entity with which the researcher has a relationship.

Where there has been a potential breach of this policy or a host organisation’s policy on conflicts, we should be informed as soon as possible about the issues identified and the actions taken. Any breaches should be handled in accordance with our research misconduct policy.

Wellcome-funded researchers and host organisations must provide to us on request:

• copies of the organisation’s conflicts of interest policy, monitoring procedures and decisions
• current information about consultancies, advisory roles, directorships and other relationships of relevance to this policy, together with details of any relevant income and shareholdings
• all other relevant information or documentation required for us to review the management of a conflict of interest.

If a researcher or host organisation breaches this policy we will consider this to be a breach of our grant conditions and we may suspend or terminate the relevant award.

We may also audit the host organisation’s processes more widely.

This policy was updated in October 2018.