Linkage Projects 2020 Round 3 Announcement Banner

Identifying and Handling a Conflict of Interest in NCGP processes

The ARC Conflict of Interest and Confidentiality Policy (Policy) is designed so that all actual, potential or perceived conflict of interests (COIs) are disclosed.

Management of COIs in accordance with the Policy maintains public confidence in the ARC’s business processes and administration of Australian Government resources including ARC-funded projects and research outcomes.

The Policy applies to ARC staff and officials, consultants, assessors, reviewers, Administering Organisations (AOs), and researchers named in ARC grant applications and involved in ARC-funded projects. The information on this page is designed to assist ARC assessors and participants on ARC grant applications to apply the Policy.

For the implementation of the Policy the ARC distinguishes between organisational and individual COIs.

Organisational COI

An individual may be considered to have a COI with an organisation for a number of reasons including, but not limited to, if that individual:

  • is employed by that organisation;
  • has been employed by that organisation within the past 2 years;
  • has an arrangement for future employment or is negotiating employment at that organisation;
  • holds a financial interest in that organisation;
  • is affiliated with or holds an appointment with that organisation, but only where the individual would be perceived to have a COI regarding grant applications or funded projects involving that organisation (e.g. where a researcher holds an honorary position and receives financial support). Non-remunerated appointments are not considered to give rise to a COI unless other factors (such as collaboration or co-authorship, appointments enabling strategic decisions over research in the organisation or association with a sponsored talent recruitment program from a country other than Australia) are also present.

Handling of organisational COIs

All individuals involved with any ARC business must maintain an up-to-date Research

Management System (RMS) profile, including disclosure of material personal interests, current employment details and previous employment history within the past 2 years. This

information will assist the ARC with the identification and management of organisational COIs.

Individuals participating in ARC grant applications and ARC-funded projects must declare their material personal interests (including organisational COIs with participating organisations) to the AO in accordance with their institution’s COI policies and procedures, the relevant ARC Grant Guidelines and Grant Agreement and the Policy.

Individual COIs

An individual may be considered to have a COI with a named participant on a grant application or funded project for a number of reasons including, but not limited to, if that individual:

  • has a close personal relationship (including enmity) with that named participant;
  • has a professional relationship with that named participant including:
    • currently holds, or has held within the past 2 years, funding conjointly with that named participant;
    • has a current application or is negotiating an application for funding with that named participant;
    • has been a collaborator or co-author with that named participant on a research output within the past 4 years;
    • has been a co-editor with that named participant of a book, journal, compendium, or conference proceedings within the past 2 years;
    • has been a postgraduate student or supervisor of that named participant within the past 5 years;
  • could otherwise be perceived to benefit materially from the awarding of funding to the grant application involving that named participant.

An individual may also be considered to have a COI if that individual has a material personal interest that conflicts with their obligations to the ARC:

  • as an ARC assessor, either a Detailed Assessor or member of the Selection Advisory Committee (General Assessor); or
  • under the conditions of a grant for ARC-funded research.

Handling of individual COIs

Assessors reviewing an ARC grant application who have identified a COI must reject the grant application assigned in RMS to assist the ARC in the management of COIs.

Individuals applying for ARC funding can nominate persons whom they do not wish to assess a grant application by submitting a Request Not to Assess (RNTA) to the ARC through their Research Office. However, they should familiarise themselves with the above information before submitting an RNTA, as in many cases the submission of a RNTA may not be necessary. Note that the RNTA process is not a permanent exclusion of an individual from assessing another individual’s grant application, but is applied as an exclusion for a specified funding round.

Declaration of material personal interests

Individuals must consider and disclose their material personal interests in all areas, including:

  • professional positions
  • membership of committees of other organisations
  • consultancies
  • boards of directors
  • advisory groups
  • professional relationships
  • outside employment (within the past 2 years)
  • family and personal relationships
  • financial interests, including receiving recompense in the form of cash, services or equipment from other parties to support research activities, including financial support from a country other than Australia and participation in a sponsored talent recruitment program from a country other than Australia, or
  • associations or affiliations with a government, intelligence organisation, government owned enterprise, military and/or police organisation in a country other than Australia.

The ARC’s expectation is that RMS profile information is kept up-to-date during the individual’s engagement with the ARC as an assessor or participant on an ARC-funded project.

The identification of a material personal interest does not prevent an individual from applying or holding ARC grants but does ensure the transparency of interests of those involved in ARC business.

Declarations of COIs for each researcher involved in an ARC-funded research project

Section 49(2)(ea) of the Australian Research Council Act 2001 requires each researcher involved in ARC-funded research projects to declare all actual, potential or perceived COIs relevant to that project, to the ARC.

The AOs are responsible for collecting declarations of COIs from researchers.

Before the commencement of an ARC-funded research project, the AO must declare to the ARC:

  • any researchers’ actual, potential or perceived COI and provide an assurance by declaration that these conflicts are being managed; or
  • that no researcher COIs have been declared in relation to the research project.

Throughout the project and following the initial declaration, the AO must advise the ARC if there is a material change in COI. This includes changes to researchers, changes to existing COIs and new COIs for existing researchers.

Following a declaration, the ARC has:

  • responsibility for reviewing and accepting the AOs’ COI declarations in RMS; and
  • the right to take any additional steps as permitted under the Grant Agreement (e.g. seek additional information if needed).