First Databank UK Ltd (“We” or “FDB”) Declaration of Interest policy and handling potential conflicts. First Databank UK Ltd is a private company registered in England, No. 01880682. Registered office: Swallowtail House, Grenadier Road, Exeter, EX1 3LH
FDB is committed to ensuring the independence and integrity of the content, solutions and services it provides and strives to be transparent about any interests that our users, customers and partners may want to know about.
The purpose of this policy is to provide guidance to all employees, contractors and consultants who contribute to a solution so FDB can achieve transparency about any personal or organisational interests that might be seen as a conflict of interest in relation to the task a person is being asked to do. This policy contains standards of conduct and practice that you must follow when contributing to an FDB solution.
It is FDB policy to have an open, transparent, fair, objective, customer-focussed, yet accountable process for the declaration of interests and how any possible conflict of interest (COI) will be handled. FDB believes anyone who is involved and can influence the conception; creation and delivery of content, solutions and services should complete a declaration of interest annually including editorial staff; product team and contractors.
COI are potential sources of bias such as financial benefit or a personal relationship which may influence an individual’s judgement and may arise when a person has a personal or organisational interest that might be seen as a COI in relation to the task a person is being asked to do for FDB.
- Conflict of Interest
Definition: A COI is a situation in which a person or organisation is involved in multiple interests, financial interest, or otherwise, one of which could possibly corrupt the motivation of the individual or organisation. The presence of a conflict of interest is independent of the occurrence of impropriety.
A competing interest is anything that interferes with, or could reasonably be perceived as interfering with, the full and objective presentation, peer review, editorial decision-making, or publication of research or non-research articles submitted. Competing interests can be financial or non-financial, professional or personal. Competing interests can arise in relationship to an organisation or another person.
A COI arises when the judgement of someone involved in the work of FDB may be compromised, by financial or other considerations set out in the policy. This policy applies to everyone involved in the conception; creation and delivery of content, solutions and services.
We ask people to be as clear and specific as possible about the activities, relationships and views they are declaring. We do not consider personal financial interests to be present in the case of assets over which individuals have no control, such as unit trusts or occupational pension funds.
- Categories of COI
The policy is intended as a guide to the kind of interests that should be declared, if in doubt all interests should be declared
- What is a financial COI?
FDB wants to hear about a personal financial interest that might conflict with the work you are doing or have been asked to do, examples would include where an individual receives benefits from a third party who is not their main employer or where an individual owns stocks and shares; patents or other assets. We ask individuals to be as clear and specific as possible about the activities, relationships and views they are declaring. We may ask for more details about any declaration for example what honorariums were for and how much they were for.
Examples include: paid consultancy; reimbursement of fees; ownership of stocks and shares; acting as an expert witness
- What is a Non-financial COI?
Non-financial interests can take many forms including personal or professional relations with organisations or individuals. The interests which should be declared are unpaid positions that might have a bearing on the solution or service being delivered. You should also declare any strongly held beliefs where they are relevant to the task being undertaken.
Examples include: unpaid advisory position to a commercial organisation; a position of trust in a charity or voluntary organisation;
- Dealing with a Declaration of Interest
All declaration of interests will be reviewed by the relevant Line Manager in the first instance and it will normally be sufficient to disclose the interest.
- Recognising a Conflict of Interest
COI that are considered to be problematic are investigated and once the facts have been collected and checked the Head of Department will review. If the COI cannot be resolved, it may be appropriate to escalate to the relevant Leadership Team member for resolution.
- Managing a Conflict of Interest
If a COI is identified, FDB shall take steps to prevent the COI from affecting decision making by:
- Identifying an alternative way forward which doesn’t involve the COI (if appropriate); and/or
- take appropriate steps to manage the COI, which will require the person affected to be removed from the issue unless and until such COI is resolved.
As a publisher of data (rather than opinion or judgement), the opportunity for private capacity interests to improperly influence the performance of official duties and responsibility, and to directly or indirectly impact the data contained within our solutions is limited.
A COI (or any Declaration of Interest) shall be stored within the individual’s confidential employee file or supplier record for reference and auditing purposes. To ensure FDB’s ongoing compliance with the Data Protection Act, FDB do not make Declaration(s) of Interest available to the public.
- Collecting and storage of COI
Conflict of interest forms will be collected annually and will be stored electronically and retain paper copies for 36 months.
Appendix A: Declaration of Interest form
A declaration of interest form needs to be completed on appointment or annually. The form will be reviewed annually and also in the event that any potential interest arises during the course of the employment or contract. We would like to know about interests in the 36 months before the declaration and those known to be going to occur during the next 12 months.
I confirm that my name is not currently removed, suspended or withdrawn from the relevant professional register in any country.
I understand it is my responsibility to inform FDB if, during my role, my name is removed from the relevant professional register in any country.
I declare that I have read and understood the First Databank UK Ltd Declaration of Interest policy and I request that the following interests to be recorded.
|Job role:||Role at FDB:
|Place of work:|
|Interest to be declared:
|Signature of person making the declaration||Date:|
|Signature of Line Manager or Head of Function||Date:|
|Managing the potential conflict: (Line Manager or Head of Function to provide details how the potential conflict will be managed)
If submitting this form electronically please type your name in the relevant space, electronic signatures will be treated as authentic.