Conflict of Interest Policy

1. Policy Statement

Brussels College is committed to ensuring that all decisions and actions are made in the best interests of the institution and its stakeholders, free from undue influence of personal interests. This Conflict of Interest Policy establishes clear procedures for identifying, disclosing, and managing situations where personal interests may conflict with professional responsibilities. Transparency, objectivity, and integrity are fundamental to maintaining trust and credibility in all our activities.

2. Scope and Application

This policy applies to:

• All members of the Board of Governors and senior management
• All employees (academic, administrative, research, and support staff)
• Committee members and working group participants
• Consultants, contractors, and advisors engaged by Brussels College
• Students in positions of authority or representation (student union officers, course representatives)

3. Definitions

3.1 Conflict of Interest

A conflict of interest arises when an individual's personal interests, relationships, or activities could inappropriately influence their professional judgment, decisions, or actions on behalf of Brussels College.

3.2 Types of Conflicts

Type	Description	Example
Actual Conflict	A real conflict exists between personal and institutional interests	Selecting your spouse's company as a supplier without competitive tendering
Potential Conflict	A situation that could develop into an actual conflict	Being offered a consultancy role with a partner institution while negotiating contracts
Perceived Conflict	Appears to others as a conflict even if not actually influencing decisions	Recruiting a family member to your department (even via fair process)
Financial Conflict	Personal financial gain from institutional decisions	Owning shares in a company bidding for college contracts
Relational Conflict	Personal relationships affecting professional judgment	Supervising a research project led by a close friend or relative
Professional Conflict	Competing professional interests or dual roles	Serving on the board of a competing institution

3.3 Personal Interests

Personal interests that may create conflicts include:

• Financial Interests: Ownership, investments, employment, consultancy fees, honoraria
• Personal Relationships: Family members, close friends, romantic partners
• Professional Activities: External employment, board memberships, advisory roles
• Reputational Interests: Personal reputation, research standing, career advancement
• Ideological Interests: Strong personal beliefs, political affiliations, advocacy positions

4. Disclosure Requirements

4.1 Mandatory Disclosure

All individuals covered by this policy must disclose:

4.2 What to Disclose

• Financial Interests:
  • Ownership or investment in companies doing business with Brussels College
  • External paid employment or consultancy arrangements
  • Honoraria, speaker fees, or gifts exceeding €50 from external organizations
  • Royalties from intellectual property related to your work
• Personal Relationships:
  • Family members employed by Brussels College or associated organizations
  • Close personal relationships with students, colleagues, or stakeholders
  • Relationships with suppliers, contractors, or partners
• External Activities:
  • Board memberships or trustee roles
  • Advisory positions or consulting arrangements
  • Political candidacy or significant political involvement
  • Ownership or management of external businesses

4.3 Disclosure Procedures

Annual Disclosure:

• All staff and governors complete an annual Conflict of Interest Declaration Form
• Forms are submitted by September 1st each academic year
• Declarations are reviewed and retained by the Vice Rector's office

Ad Hoc Disclosure:

• New conflicts must be disclosed within 7 days of becoming aware
• Disclosure at the start of any meeting, decision, or process where a conflict may arise
• Immediate verbal disclosure followed by written confirmation

How to Disclose:

• Complete the Conflict of Interest Declaration Form (available from HR or governance office)
• Submit to Vice Rector: i.chiloglu@brucol.be
• Declare verbally at meetings and request recording in minutes

5. Common Conflict Scenarios

5.1 Recruitment and Employment

Conflicts arise when:

• A family member or close friend applies for a position you are involved in recruiting
• You have a financial relationship with a candidate's employer
• You supervise or manage a relative or partner

Management approach:

• Disclose the relationship immediately to HR
• Recuse yourself from the recruitment panel and decision-making
• Ensure an independent panel member makes hiring decisions
• Avoid direct line management of family members where possible

5.2 Procurement and Contracting

Conflicts arise when:

• You have a financial interest in a supplier bidding for contracts
• A family member works for a company seeking business with Brussels College
• You receive gifts or hospitality from potential suppliers during procurement processes

Management approach:

• Disclose the interest before procurement begins
• Remove yourself from evaluation, negotiation, and award decisions
• Ensure independent evaluation and competitive tendering
• Document all decisions and the management of the conflict

5.3 Academic Assessment and Supervision

Conflicts arise when:

• Assessing or supervising a family member, friend, or partner
• Tutoring students privately for a fee outside official duties
• Financial or personal relationships with external examiners or moderators

Management approach:

• Disclose relationships to academic administration immediately
• Transfer supervision or assessment to another qualified staff member
• Implement independent moderation or external examination
• Prohibit private tutoring of your own students

5.4 Research and Intellectual Property

Conflicts arise when:

• You have financial interests in companies funding your research
• Publishing research outcomes could benefit your personal investments
• Serving as a consultant to organizations related to your research
• Intellectual property rights create competing interests

Management approach:

• Disclose all funding sources and financial relationships
• Establish independent oversight of research design and data analysis
• Declare conflicts in publications and grant applications
• Separate decision-making on IP commercialization from inventors

5.5 External Activities and Secondary Employment

Conflicts arise when:

• External work competes with Brussels College activities
• Using college resources or time for private business
• Conflicts between external board duties and college interests

Management approach:

• Seek prior approval for significant external activities
• Ensure external work does not interfere with college duties
• Do not use college resources for private benefit
• Recuse yourself from decisions where external interests conflict

6. Management of Conflicts

6.1 Management Strategies

Strategy	Description	When Appropriate
Disclosure Only	Record the conflict but allow continued participation	Minor or perceived conflicts that can be transparently managed
Restriction	Limit access to certain information or aspects of decision-making	Moderate conflicts where some involvement is necessary
Recusal/Abstention	Withdraw from discussions and decisions on the conflicted matter	Significant conflicts where objectivity could be compromised
Reassignment	Transfer responsibilities to another individual	Ongoing conflicts in supervision, assessment, or management
Divestment	Remove the conflicting interest (e.g., sell shares, resign external role)	Severe conflicts that cannot otherwise be managed
Prohibition	Prohibit the activity creating the conflict	Unmanageable conflicts or those violating policy

6.2 Decision-Making Process

1. Disclosure: Individual discloses the conflict to the Vice Rector or line manager
2. Assessment: Evaluate the nature, severity, and impact of the conflict
3. Management Plan: Determine appropriate management strategy
4. Documentation: Record the conflict and management approach
5. Communication: Inform relevant parties of the management plan
6. Monitoring: Review ongoing effectiveness of management measures

6.3 Register of Interests

Brussels College maintains a confidential Register of Interests containing:

• All disclosed conflicts of interest
• Management strategies implemented
• Review dates and outcomes
• Historical records for audit and accountability

The Register is maintained by the Vice Rector's office and is accessible to:

• Senior management for decision-making purposes
• Internal and external auditors
• Regulatory bodies upon request

7. Specific Policy Areas

7.1 Gifts and Hospitality

See also: Anti-Bribery Policy

• Gifts under €50: Generally acceptable if disclosed
• Gifts €50-€100: Require line manager approval and disclosure
• Gifts over €100: Require Vice Rector approval before acceptance
• Cash or cash equivalents: Never acceptable under any circumstances
• All gifts must be declared in the Register of Interests

7.2 External Employment and Consultancy

Staff wishing to undertake external work must:

• Seek prior written approval from their line manager and Vice Rector
• Ensure external work does not exceed 20% of full-time equivalent hours
• Confirm no conflicts with Brussels College teaching, research, or administrative duties
• Not use college resources, facilities, or time for private work
• Declare all income from external activities in annual disclosures

7.3 Intellectual Property and Commercialization

• Staff involved in creating IP must disclose all external financial interests related to commercialization
• Decisions on licensing, spin-outs, or commercialization are made independently of inventors
• Revenue-sharing arrangements are transparent and follow institutional policies
• Conflicts are managed through independent oversight and evaluation

8. Consequences of Non-Compliance

8.1 Failure to Disclose

Failure to disclose conflicts of interest may result in:

• Formal investigation under disciplinary procedures
• Written warning or reprimand
• Suspension or termination of employment
• Reversal of decisions made while conflict existed
• Recovery of financial benefits improperly obtained
• Referral to professional regulatory bodies or law enforcement

8.2 Mismanagement of Conflicts

Participating in decisions despite a disclosed conflict without proper management may result in:

• Invalidation of decisions or contracts
• Disciplinary action against the individual and their supervisor
• Reputational damage to the institution
• Legal action by affected parties

9. Training and Awareness

9.1 Mandatory Training

• Induction: All new staff receive conflict of interest training within the first month
• Annual Refresher: All staff complete annual training on conflicts and ethical conduct
• Specialized Training: Enhanced training for senior management, procurement staff, and researchers
• Board Training: Governors receive conflict of interest and governance training annually

9.2 Awareness Campaigns

Brussels College promotes awareness through:

• Regular communications on ethical conduct and transparency
• Case studies and examples of conflict management
• Resources and guidance materials on the staff intranet
• Annual ethics and integrity awareness week

10. Governance and Oversight

10.1 Board of Governors

The Board has ultimate responsibility for:

• Approving and reviewing this Conflict of Interest Policy
• Ensuring robust systems for identifying and managing conflicts
• Setting the tone for ethical conduct and integrity
• Managing their own conflicts in board decisions

10.2 Vice Rector Responsibilities

• Maintain the Register of Interests
• Provide advice on conflict identification and management
• Investigate alleged failures to disclose conflicts
• Report significant conflicts and breaches to the Board
• Coordinate conflict of interest training

10.3 Audit and Review

• Internal audit reviews conflict management processes annually
• External auditors assess compliance with conflict policies
• Register of Interests is reviewed quarterly for completeness and accuracy
• Policy effectiveness is evaluated through surveys and incident analysis

11. Policy Review

This Conflict of Interest Policy is reviewed annually and updated to reflect:

• Changes in legislation and regulatory requirements
• Best practices in governance and ethics
• Lessons learned from conflict management cases
• Feedback from staff, governors, and stakeholders
• Organizational changes and emerging risk areas

12. Contact Information

Vice Rector (Conflict of Interest Officer):
Dr. İbrahim Çıloğlu
Email: i.chiloglu@brucol.be
Phone: +32 471 09 6641

General Enquiries:
Email: office@brucol.be
Phone: +32 471 09 6641

Anonymous Reporting:
Email: whistleblowing@brucol.be