Conflict of Interest Policy

Purpose

An-Najah National University (ANNU) is committed to the principles of integrity, transparency, accountability, fairness, and ethical conduct in all academic, administrative, financial, research, and community engagement activities. This Conflict-of-Interest Policy establishes a framework for identifying, disclosing, managing, and mitigating actual, potential, or perceived conflicts of interest that may compromise the University's mission, reputation, or decision-making processes.

The University recognizes that conflicts of interest are not inherently unethical; however, failure to disclose and appropriately manage such conflicts may undermine public trust and institutional integrity.

Scope

This Policy applies to all individuals acting on behalf of the University, including:

• Members of the Board of Trustees.

• Members of the University Council and governing bodies.

• The President, Vice Presidents, Assistants, and senior administrators.

• Academic staff and faculty members.

• Administrative and technical staff.

• Researchers, research assistants, and project personnel.

• Members of standing and ad hoc committees.

• Consultants, contractors, and external experts engaged by the University.

• Students serving in representative, governance, leadership, or decision-making roles.

Policy Statement

All University personnel shall perform their duties objectively, impartially, and in the best interests of the University. Personal, financial, professional, family, or external interests must not improperly influence University decisions, actions, or resource allocation.

Individuals are required to disclose conflicts of interest promptly and cooperate fully with measures implemented to manage or eliminate such conflicts.

Definitions

• Conflict of Interest: A conflict of interest exists when an individual's personal, financial, professional, family, or other external interests interfere, appear to interfere, or have the potential to interfere with the proper performance of their duties and responsibilities to the University.

• Actual Conflict of Interest: A situation in which a direct conflict currently exists between personal interests and official responsibilities.

• Potential Conflict of Interest: A situation in which personal interests may reasonably be expected to create a conflict in the future.

• Perceived Conflict of Interest: A situation in which a reasonable observer may conclude that an individual's objectivity could be compromised, regardless of whether an actual conflict exists.

Examples of Conflicts of Interest

Conflicts of interest may include, but are not limited to:

1. Financial Interests

   1. Ownership of shares, investments, or financial interests in organizations conducting business with the University.

   2. Receiving financial benefits resulting from university decisions.

   3. Personal involvement in transactions that may provide direct or indirect financial gain.

2. Family and Personal Relationships

   1. Participating in decisions regarding the recruitment, supervision, promotion, evaluation, or compensation of relatives or close associates.

   2. Influencing decisions affecting family members or individuals with whom a close personal relationship exists.

3. Procurement and Contracting

4. Participating in tender evaluations, procurement decisions, or contract awards involving entities with which the individual has a personal or financial relationship.

5. Receiving gifts, favors, hospitality, or benefits from suppliers, contractors, or service providers.

4. Outside Employment and Professional Activities

   1. Holding external employment, consulting positions, or business interests that conflict with university responsibilities.

   2. Using University resources, facilities, information, or reputation for personal gain.

5. Research Activities

   1. Failing to disclose funding sources or financial interests related to research projects.

   2. Influencing research design, conduct, interpretation, or publication for personal benefit.

   3. Maintaining undisclosed relationships with sponsors that may affect research integrity.

Responsibilities of University Personnel

All covered individuals shall:

1. Act honestly, fairly, and in the best interests of the University.

2. Avoid situations that may create conflicts of interest whenever possible.

3. Promptly disclose actual, potential, or perceived conflicts of interest.

4. Refrain from participating in discussions, evaluations, recommendations, or decisions related to the conflict.

5. Cooperate with all investigations, reviews, and management procedures related to conflicts of interest.

Disclosure Requirements

1. Initial Disclosure

Individuals shall disclose relevant interests upon:

• Appointment or employment.

• Assignment to a management or leadership position.

• Membership on committees or governing bodies.

• Participation in research projects, grants, procurement activities, or contractual arrangements.

• Ongoing Disclosure

Individuals must update their disclosures within thirty (30) days of any material change in circumstances that may give rise to a conflict of interest.

3. Disclosure Forms

The University shall maintain official Conflict of Interest Disclosure Forms and records in accordance with applicable confidentiality requirements.

Management of Conflicts of Interest

Upon identification of a conflict of interest, the University may implement one or more of the following measures:

• Recusal from discussions, evaluations, or decisions.

• Transfer of decision-making authority.

• Independent review or oversight.

• Modification of duties or responsibilities.

• Divestment of conflicting interests where appropriate.

• Removal from committees, projects, or activities associated with the conflict.

The selected management approach shall be proportionate to the nature and significance of the conflict.

Gifts, Hospitality, and Benefits

University personnel shall not:

• Solicit gifts, favors, services, or benefits from individuals or organizations seeking to influence University decisions.

• Accept gifts or benefits that may compromise, or appear to compromise, impartiality and professional judgment.

Nominal and customary gifts of symbolic value may be accepted when permitted under university regulations and applicable laws.

Research-Related Conflicts of Interest

Researchers are required to:

• Disclose all sources of research funding and sponsorship.

• Declare any financial or personal interests related to research activities.

• Adhere to the University's Research Integrity and Research Ethics requirements.

• Ensure that research outcomes are free from improper influence.

The University may establish additional procedures governing conflicts of interest in research and innovation activities.

Confidentiality and Protection Against Retaliation

The University shall:

• Maintain confidentiality regarding disclosures and investigations to the extent permitted by law.

• Protect individuals who report concerns in good faith.

• Prohibit retaliation, intimidation, discrimination, or adverse treatment against whistleblowers or individuals participating in investigations.

Institutional Responsibilities

The University unit responsible for governance, compliance, internal audit, legal affairs, or other designated authority shall:

• Receive and review disclosures.

• Assess conflict-of-interest cases.

• Recommend appropriate management measures.

• Maintain disclosure records.

• Monitor compliance with this Policy.

• Report significant cases to senior leadership and governing bodies as appropriate.

Non-Compliance and Disciplinary Actions

Failure to comply with this Policy may include:

• Failure to disclose a conflict of interest.

• Submission of misleading, incomplete, or inaccurate information.

• Participation in decisions despite the existence of a conflict.

Violations may result in disciplinary action in accordance with university regulations, policies, employment contracts, and applicable laws.

Disciplinary measures may include:

• Written warnings.

• Removal from committees or projects.

• Administrative sanctions.

• Employment-related disciplinary procedures.

• Other corrective actions deemed appropriate by the University.

Awareness and Training

The University shall promote awareness of this Policy through:

• Employee orientation programs.

• Periodic training sessions.

• Governance and ethics workshops.

• Publication of the Policy on the University's official website and internal communication channels.

Monitoring and Review

This Policy shall be reviewed periodically, at least once every three (3) years, or whenever significant legislative, regulatory, or institutional changes occur.

The review process shall ensure continued alignment with international best practices in governance, ethics, integrity, and accountability.

 

Effective Date: December 12, 2018

Review Date: Jun 25, 2025