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Confidentiality Obligations and Conflict of Interest Guidelines for ARC College of Experts Members

• Introduction
• Confidentiality obligations
• Disclosing Conflicts of Interest
• Australian National Audit Office Report
• Conflict of Interest Guidelines
• Requirements for members

Introduction

As a public funding body the ARC is required to maintain a high standard of professionalism and ethical conduct in its operations.  In particular, the selection and assessment processes must be, and be seen to be, operating fairly, effectively and impartially - it is essential that we maintain public confidence in the integrity of the peer review process.  Consequently, we require members of the College of Experts to provide assurances to the ARC that they will abide by the ARC's confidentiality requirements and will disclose to it any conflicts of interest related to their official duties as members.

Confidentiality obligations

The funding proposals provided by applicants and the assessments provided by assessors are given and received in confidence.  These documents must be handled and treated as confidential material and are to be used only for assessment purposes for ARC funding schemes.  In order to preserve confidentiality, members must not, without the prior written approval of the ARC, allow any non-public material contained within a funding proposal to be made public or disclosed to any person other than the ARC, its staff, the ARC College of Experts members or selection advisory committee members (ARC Representatives).  Members should not discuss assessments with any other parties at any stage, nor reveal to people who are not ARC Representatives details about any assessment unless authorised to do so, either before or after the final decisions have been released.

Furthermore, in order to comply with ethical standards, material contained in proposals must be used or disclosed by members only for the purposes of providing assessments to the ARC. It is unethical and possibly unlawful for members to use any intellectual property contained in a proposal.  To protect confidentiality, members should destroy all copies of the proposals they receive as soon as the assessment process is completed.

In preparing advice for the Minister, the ARC consults widely and often enters into public debate on issues relevant to its responsibilities.  Once advice is developed, however, it is essential that it remain confidential until the Minister has considered it and released it into the public domain.

Disclosing Conflicts of Interest

Conflicts of interest may arise from time to time.  A conflict of interest arises in relation to a member's official duties as a member of the College, if the member has interests which could improperly influence the performance of their official duties and responsibilities.  

A member should not assess any proposal for which he or she has, or may reasonably be perceived to have, a conflict of interest and/or potential conflict of interest.

Conflicts of interest must be disclosed and dealt with.  Members may experience actual or potential conflicts of interest between their activities on behalf of the ARC and those arising from personal or professional responsibilities.  These guidelines are designed to ensure that all such conflicts are identified and addressed in a rigorous and transparent way.  Prior to, or when, assessing proposals, if you consider that you may have a conflict of interest and/or potential conflict of interest, please advise the ARC.

Australian National Audit Office Report

In 2006 the Australian National Audit Office released ANAO Report No. 38 2005-06: The Australian Research Council's Management of Research Grants.  The report made specific recommendations that the ARC strengthen its processes for managing conflicts of interest for the ARC College of Experts and other ARC committee members.  It recommended that the ARC do this by revising these Guidelines in line with better practice, including the ANAO Better Practice Guide – Administration of Grants by:

• reviewing conflict of interest declarations annually, as a way of maintaining compliance with conflict of interest principles;
• developing new protocols for a register of private interests, and establishing and regularly revising the register; and
• clearly identifying responsibility for managing and resolving conflict of interest matters and implementing a regular monitoring process.

The ARC accepted the ANAO recommendations, and these guidelines incorporate them.

Conflict of Interest Guidelines

A conflict of interest should be declared wherever there is a potential for a member to gain from access to non-public information or the results of non-public discussions or decision-making processes.  This may occur if the member has business or financial interests, including holding a company directorship or shareholding, a financial investment, or a consultancy or a grant which could lead to financial gain to the member in circumstances where the member has access to information or is able to influence decision-making such that he or she will benefit directly from being granted access to information or involved in the decision-making.

A conflict of interest may arise from members' affiliations with other organisations or people, including employment, professional or personal relationships.  A member employed by a university, for example, should declare an interest in circumstances in which there is consideration by the committee of individual proposals, projects, grants or consultancies associated with that university.

With respect to members' personal relationships, a conflict of interest may arise, for example, from a proposal for a consultancy or grant from a member's partner or relative, a close personal friend or a close professional colleague.

Actual or potential non-pecuniary conflict of interest may arise from a member's simultaneous appointment to, or employment, consultancy or other involvement with, another organisation or body that is in some way involved with the advice or policies which are being developed or programs being administered.  A situation may arise in which the interests of the ARC and the other body or organisation are in conflict, or if access to information arising from committee membership could be used to unfair advantage if divulged to the other organisation or body.  In certain circumstances, the member may need to consider resigning committee membership, or severing links with the other organisation or body, as appropriate, to avoid a continued conflict of interest.  In less extreme cases, the member may need to refrain from, or constrain participation in, relevant discussions or activities of the other organisation or body in order to protect the ARC's interests.

The ARC recognises that, in certain specialised areas of research or consultancy, there may be a very limited number of individuals, project teams or organisations with the expertise and knowledge required.  The requirements (see below) for declaring an interest must nevertheless be applied if a conflict of interest arises.  It may be possible to foresee a potential conflict of interest at some future time and to take steps to prevent it from actually arising.

These guidelines do not attempt to cover all cases where a conflict of interest may occur.  Members may find themselves in situations that are not clear cut or where there is a genuine doubt as to whether a conflict of interest should be declared.  In such circumstances, members should err on the side of caution and declare a conflict of interest or a potential conflict of interest. 

Requirements for members

Before commencing their official responsibilities, members of the ARC College of Experts must provide the ARC with a written statement of any interest (Attachment A) that the member holds that may relate to the functions of the College. 

If the member has, or acquires, an interest, pecuniary or otherwise, that could conflict with the proper performance of her or his functions as a College member, he or she must disclose details of the nature of the interest to the ARC.  In cases where a member declares a conflict of interest in relation to a matter under consideration by the ARC or one of its committees, the ARC/committee should determine the extent to which that member may be involved in discussion or decisions concerning that matter.

The disclosure must be made as soon as possible after the relevant facts come to the member's knowledge, and must be recorded by the ARC in minutes of the meeting, workbooks and/or other relevant documentation.  Unless the ARC/ ARC College of Experts/ committee of the ARC College of Experts otherwise determines, the member:

[Members are asked to read the Guidelines, complete and return Attachments A and B to the ARC].

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