Conflict of Interest Policy

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Legal Affairs
Conflict of Interest Policy
MBZUAI-LAS-CONFINTR-POL-V1.0
Effective: 11/11/2021

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Table of Contents
1. Document Control Information..................................................................................................... 3
2. Glossary of Terms ........................................................................................................................ 3
3. Introduction ................................................................................................................................ 4
4. Objective .................................................................................................................................... 4
5. Scope ......................................................................................................................................... 4
6. Conflict of Interest Policy ............................................................................................................. 4
6.1. Principles............................................................................................................................ 4
6.2. Determining a Conflict of Interest ........................................................................................ 5
6.3. Disclosure of a Conflict of Interest........................................................................................ 5
6.4. Failure to Disclose a Conflict of Interest ................................................................................ 5
6.5. Resolutions of Conflicts of Interest ....................................................................................... 5
7. Related Documents .....................................................................................................................6
8. Version History............................................................................................................................6

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1. Document Control Information
Policy Name Conflict of Interest
Document Name/ Reference Number MBZUAI-LAS-CONFINTR-POL-V0.1
Department Name Legal Affairs
Owner/ Updated – Developed by General Counsel
Version Number 1.0
Approval Date 11/11/2021
Approved By President
Date of Last Revision 16/11/2023
Date for Next Revision 16/11/2025
For Office Use – Keywords for search function
Policy Review
Person responsible Workflow Date
General Counsel Initiate, Review First approved version 01 Oct 2020, minor
change 16 Nov 2023
Head of IEQA Review 17 Nov 2023
President Approve 11 Nov 2021
2. Glossary of Terms
Term Definition
Conflict of Interest
A situation in which any personnel has a private or personal interest that is likely to
appear to influence the objective exercise of an aspect(s) of their University duties.
For the purpose of this Policy, the term ‘conflict of interest’ includes perceived, potential
and actual conflicts of interest.
• A perceived conflict of interest is one which a reasonable person would consider
likely to compromise objectivity;
• A potential conflict of interest is a situation which could develop into an actual or
perceived conflict of interest;
• Financial interest refers to anything of non-trivial monetary value;
• Non-financial interest refers to any non-financial benefit or advantage, including,
but not limited to, enhancement of an individual’s career, education or
professional reputation, access to privileged information or facilities.
• Relative or friend: Any member of a personnel’s close family or friend, likely to
appear to a reasonable person to influence their objectivity.
Department MBZUAI- Legal Affairs Approval Date 11/11/2021
Policy Number MBZUAI-LAS-CONFINTR-POL-V1.0 Revision Date 16/12/2025
Policy Conflict of Interest Policy Owner General Counsel

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3. Introduction
The University recognizes that its personnel and students have diverse interests and contacts within the local,
national and international community. These links are often in the public interest, as well as beneficial to the
University and to individuals. It is also possible that such connections may give rise to potential conflicts of
interest.
The University recognizes that, in general, individuals will recognize conflicts of interest and will want to
ensure that there can be no perception of their receiving an inappropriate advantage, and that they are
personally beyond suspicion.
In most cases, potential conflicts of interest will be easily avoided or resolved by informal action, either by
the individual concerned or through discussion with their manager.
4. Objective
The purpose of this Policy is to:
• Assist in identifying conflicts of interest;
• Establish a system for disclosure of conflicts of interest;
• Provide guidance to those responsible for dealing with conflicts of interest;
• Assist in the resolution of conflicts of interest in order to protect the University and its personnel.
5. Scope
This policy applies to all employees and students (referred to collectively as “personnel”) of the University
and relates to any actual, perceived or potential conflicts of interest arising in connection with University
activities.
6. Conflict of Interest Policy
6.1. Principles
6.1.1. There is a need to balance the rights and responsibilities of personnel and those of the University
in relation to the management of conflict of interest. Each personnel has an obligation to act in
the best interests of the University in relation to their University duties, activities and
employment. The University has obligations to its personnel:
• not to interfere in their private concerns where these have no bearing on the legitimate
interests of the University; and
• to deal with issues raised under this Policy in a prompt, fair, reasonable and objective
manner, paying due attention to the effects of any actions on an personnel’s work, career
and reputation.
6.1.2. The existence of an actual, perceived or potential conflict of interest does not necessarily imply
wrongdoing on anyone’s part. However, any private, personal, or commercial interests which give rise
to such a conflict of interest must be recognized, disclosed appropriately, and either eliminated or
properly managed.
Department MBZUAI- Legal Affairs Approval Date 11/11/2021
Policy Number MBZUAI-LAS-CONFINTR-POL-V1.0 Revision Date 16/12/2025
Policy Conflict of Interest Policy Owner General Counsel

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6.2. Determining a Conflict of Interest
6.2.1. In order to determine whether a conflict of interest exists, it should be determined whether the
private, personal or commercial interest is likely to interfere, or appear to interfere with the
objective judgement the personnel should show in performing their University duties. Could
others reasonably conclude that it might influence the personnel to act other than in the interests
of the University? Serious conflicts of interest include, but are not limited to, the following points:
Personnel using their University position to:
• Influence a contract or other favorable terms for a company in which they, or a relative or
friend, had a financial interest;
• Influence employment, promotion, admission to a course of study, educational progression
or other financial or non-financial benefit for a relative or friend; or
• Obtain financial or non-financial benefits for him/herself or for a relative or friend in return
for providing advantage, or potential advantage;
• Compromising research objectivity or independence in return for financial or non-financial
benefit for them or for a relative or friend;
• Using University resources or confidential information obtained through their University
position for personal financial or non-financial benefit, or benefit to a relative or friend;
• Conducting business, employment or activity outside the University, which adversely affects
the personnel’s ability to perform their duties
6.3. Disclosure of a Conflict of Interest
6.3.1. The responsibility for identifying and avoiding conflict of interest, in the first instance, lies with the
individual personnel. If a conflict of interest situation arises, the personnel must disclose the conflict
of interest in writing, and seek a resolution. They must then take no part in the matter(s) relating to
that interest unless, and until such time as the potential conflict is resolved. All personnel are required
to submit a conflict of interest disclosure form every year, whether they have a conflict of interest to
disclose, or not.
6.4. Failure to Disclose a Conflict of Interest
6.4.1. Failure to disclose an actual or perceived conflict of interest, or to cease involvement in the situation
until the conflict has been resolved, constitutes a breach of the personnel’s contract of employment
and may result in disciplinary action, and in serious cases could result in dismissal.
6.5. Resolutions of Conflicts of Interest
6.5.1. Once a conflict has been disclosed, the line manager, or supervising faculty, is responsible for resolving
the conflict of interest as soon as is reasonably practicable, including the escalation of the matter, if
required. Until that time, the personnel must take no part in the particular activity relating to the
potential conflict. Every effort should be made to reach agreement with the personnel regarding the
solution. Resolution of the conflict may not go beyond the scope of the personnel’s contractual
obligations (explicit or implicit) without the personnel’s agreement.
Department MBZUAI- Legal Affairs Approval Date 11/11/2021
Policy Number MBZUAI-LAS-CONFINTR-POL-V1.0 Revision Date 16/12/2025
Policy Conflict of Interest Policy Owner General Counsel

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7. Related Documents
Section Related Document(s)
6.3 Link to the conflict of interest disclosure form
8. Version History
Version
number
Person responsible Date of change Comments
V1.0 General Counsel 11/11/2021 First approved version
V1.1 General Counsel 16/11/2023 Minor addition to section 6.3 disclosure of a
conflict of interest on submitting the form and
attaching the related form.
V1.2 Head of IEQA 17/02/2025 Corrected policy as the version published was
missing sections 6.1-6.3 which had been
approved in the original approval process V1.0.
Department MBZUAI- Legal Affairs Approval Date 11/11/2021
Policy Number MBZUAI-LAS-CONFINTR-POL-V1.0 Revision Date N/A
Policy Conflict of Interest Policy Owner General Counsel