Conflicts of interest policy: Wellcome funding process

A conflict of interest exists when an individual’s personal and/or professional interests or loyalties may affect their objectivity.  

A perceived conflict of interest exists when it could be reasonably considered by a third party that a conflict exists (irrespective of whether or not this is actually the case).  

Examples of conflicts of interest include: 

• Personal relationship with an applicant for funding: for example, a family member or a close family friend.
• Professional relationship with an applicant for funding: for example, a current collaborator, a recent co-author or recent supervisor (typically within the last 3 years).
• Current Applicant: where a committee member or other expert reviewer is an applicant to the same funding scheme at the same meeting. 
• ‘Double jeopardy’: where a committee member or other expert reviewer has already reviewed the same application at a different funding body.  

We expect anyone involved in the processing or assessment of applications, including but not limited to committee members, expert reviewers and staff members, to identify any real or perceived conflicts of interest they have related to the people and organisations submitting applications for review. Those external to Wellcome must inform their Wellcome contact who will record and help to manage any identified conflicts; Wellcome staff must discuss with their line manager. 

When determining possible conflicts of interest, we expect everyone to be: 

• Thorough and transparent to ensure all possible conflicts have been considered.
• Objective and consistent to ensure fairness throughout the process.
• Timely in the provision of information. 
• Accepting of Wellcome’s decision on how to manage any conflict. 

In addition to the self-identification of possible conflicts, Wellcome staff review publicly available data to determine whether an individual has a potential conflict of interest. 

When a potential conflict has been identified, Wellcome will determine the degree of materiality taking into account: 

• The closeness of the conflict; for example, a conflict relating to a collaborator with relatively minor input to a project is less material than if it relates to a principal applicant. 
• The value and nature of the potential benefit; for example, shareholding in a company that would benefit from the project would be more material than an affiliation with a university to be awarded funds. 

Committee members 

Wellcome has three levels of restriction which are used to manage material conflicts of interest. The level of restriction depends on the nature of the conflict identified, as follows:  

• Limited: when a conflict of interest has been identified but the materiality is low due to the nature of the conflict. For example, a committee member is based at the same organisation but is based in a different department or division and does not actively collaborate with any of the applicants. The committee member will have access to the application and may be present for and contribute to the discussion but will not be allowed to provide a score. 
• Recused: when a material conflict of interest has been identified. For example, the committee member has an active collaboration with the lead applicant or works in the same department. The committee member will not have access to the application and will leave the meeting for the discussion of that application.
• Excluded: when a material conflict of interest has been identified which impacts the assessment of any application.  For example, the committee member is an applicant to the same funding scheme and meeting. The committee member will not have access to any of the meeting information and will not attend the meeting. 

Written expert reviewers 

If any material conflict of interest is identified, the reviewer will not be asked to provide a review report.  

Staff members 

Conflicts of interest related to current staff members participating in the assessment of an application are handled in the same way as for an external committee member.

Staff previously employed by Wellcome-funded organisations may review applications for funding from those organisations and attend associated committee meetings. However, they may not participate in the decision-making process for those applications for a period of one year from the start date of their employment with Wellcome.