The ARC Conflict of Interest and Confidentiality Policy is designed so that all material personal interests are disclosed. This will support the identification and management of conflicts of interest in a rigorous and transparent way that ensures the integrity, legitimacy, impartiality and fairness of ARC processes and the ARC’s administration of Australian Government resources. Management of conflicts of interest in this way is designed to maintain public confidence in the ARC’s business processes and ensure that both ARC-funded projects and research outcomes supports and primarily benefits the Australian community.
For the implementation of the policy the ARC distinguishes between organisational and individual conflicts of interest.
Organisation conflicts of interest
An individual may be considered to have a conflict of interest 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 two 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 reasonably be perceived to have a conflict of interest 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 generally considered to give rise to a conflict of interest unless other factors arise (such as collaboration or co-authorship, appointments enabling strategic decisions over research in the organisation or association with a foreign sponsored talent recruitment programs) are also present.
Individual conflicts of interest
An individual may be considered to have a conflict of interest 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 two 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 four years;
- has been a co-editor with that named participant of a book, journal, compendium, or conference proceedings within the past two years;
- has been a postgraduate student or supervisor of that named participant within the past five 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 conflict of interest if that individual has a material personal interest that is in conflict with their obligations to the ARC:
- as an ARC assessor; or
- under the conditions of a grant for ARC-funded research.
Declaration of material personal interests
Individuals must consider and disclose their material personal interests in all possible areas, including:
- professional positions
- membership of committees of other organisations
- boards of directors
- advisory groups
- professional relationships
- 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 foreign financial support and participation in a foreign sponsored talent recruitment program, or
- association or affiliations with a foreign government, foreign political party, foreign state-owned enterprise and/or a foreign policy organisation.
The ARC’s expectation is that RMS profile information is kept up-to-date during the individual’s engagement with the ARC as a General Assessor or participant on an ARC-funded project.
RMS Personal Profile questions
As a result of this Policy, any named Chief Investigator (including Directors, Fellows etc.) or Partner Investigator on an ARC application or ARC funded project must maintain an update-to-date RMS profile, including disclosure of material personal interests, current employment details and previous employment history within the past two years. This information will assist the ARC with the identification and management of organisational conflicts of interest.
The below questions and answers will not be displayed in RMS to other participants or appear in any the application PDF. The information will only be visible to the individual who owns the account, the ARC staff, the research office at the Administering Organisation of the project, and the university employer of the individual if different to the Administering Organisation of the application. This is to ensure that the due diligence can occur at the university employing the researcher and the university that is responsible for the application prior to submitting the application to the ARC. Any investigator joining a currently awarded project via a formal ARC variation request will also be required to update their RMS profile.
All investigators must answer these questions truthfully and should not tailor responses or avoid listing collaborations. The ARC peer review process will continue to be based on the merits of each application and answers to the following will not impact assessments.
The new questions introduced in RMS Personal profiles are as follows:
1. Are you receiving any foreign financial support (cash or in-kind) for research activities? If yes, then specify the country/ies that you have received financial support from?
Provide details of multiple countries by clicking ‘Add’ once the country is selected.
A brief summary of the type of financial support received from each country will be required. Foreign financial support can come in many forms and can include cash, research funding, research and laboratory personnel, laboratory space, scientific materials, career advancement opportunities, promised future compensation or other types of remuneration.
Note: ‘Foreign’ means outside of Australia.
2. Are you currently, or have you previously been, associated or affiliated with a foreign sponsored talent recruitment program? If yes, then specify the program/s and the country of origin for each program.
Provide details of each program by clicking ‘Add’ once the country is selected.
Ensure that the program name, a short summary of the talent program/s, dates and financial or other support are provided for each country.
3. Are you currently associated or affiliated with a foreign government, foreign political party, foreign state owned enterprise, foreign military or foreign policy organisation?
If yes, provide details of each association/affiliation by clicking 'Add' once the affiliation type is selected. An explanation for the nature of each association/affiliation is required for each selection.
4. Have you identified and disclosed any conflicts of interests in accordance with your institution’s conflict of interest policies and procedures?
This question serves as a declaration that:
- You have one or more Conflicts of Interest (COIs) and have disclosed them to your employing institution, and if relevant, Administering Organisation(s) of ARC grant applications as required by the institution(s)'s COI policies and procedures, or
- You do not have any COIs and have followed the relevant institution(s)'s COI policies and procedures (which may include reporting you have nil COIs).
In both cases you should answer 'Yes' to this question.
A 'No' answer to this question indicates that you have a COI that you have not disclosed to your employing institution or relevant Administering Organisation(s) of ARC grant applications. In this case you will be prevented from participating on an ARC grant application.
5. Has the participant acknowledged the collection of personal information by the ARC?
The statement in the Personal Profile reads: By ticking the box, I acknowledge that personal information collected in my profile, including country of birth, date of birth, foreign relationships and conflict of interest declarations will be available to staff who have administrative roles at both my administering organisation, and the administering organisation of any applications that I am named on, and the ARC may disclose this information to other government agencies for the purposes of grant administration and legislative compliance.
If this box is not ticked and the statement acknowledged you will not be able to be a named participant on an ARC grant application.
Advice received from the ARC to date in response to questions from the university sector regarding the above is as follows:
- These questions must be completed by all participants named on an application
- Participants can consider this requirement prior to agreeing to participate on an application
- The ARC’s approach is to work with universities to ensure the identification and understanding of risks associated with research, and if risks are identified in applications. Any issues identified will be referred to the DVCR of the applicant Administering Organisation for consideration. The ARC is not a national security specialist and the ARC may seek advice from national security agencies. Funding decisions remain at the discretion of the Minister.
- The ARC peer review processes will continue to be based on assessing the merit of each application against the assessment criteria set out in Grant Guidelines.
- The ARC is not intending to publish any lists about suitable and/or unsuitable collaborators. The primary responsibility for undertaking due diligence for applications remains with the universities. Consistent with universities being applicants for ARC grants, they must undertake due diligence on the researchers and their partners prior to applying to the ARC for funding and consider the risks of the proposed research outlined in applications. The ARC still wants researchers to partner with the best in the world, and to have access to the best in the world. This is about transparency, not blocking who researchers can partner with.
- The National Interest Test (NIT) is a separate process. The NIT is about articulating the extent to which the research contributes to Australia’s national interest through its potential to have economic, commercial, environmental, social or cultural benefits to the Australian community.
If any investigator wishes to discuss their individual circumstances with the RIC team responsible for submitting their ARC application, please contact the below.
APPII team (Leah Sullivan/Angela Baklavas)
Discovery Projects - firstname.lastname@example.org
Discovery Indigenous - email@example.com
DECRA - firstname.lastname@example.org
Future Fellowships - email@example.com
Linkage Projects - firstname.lastname@example.org
Major Initiatives (Melanie Horder)
Laureate Fellowships - email@example.com
ITRP Hubs & Training Centres - firstname.lastname@example.org
Centres of Excellence - email@example.com
Special Research Initiatives – firstname.lastname@example.org
Linkage Infrastructure, Equipment & Facilities (LIEF) – email@example.com
For further advice on how to identify and manage a conflict of interest please refer to the University of Melbourne Conflict of Interest web page.