Conflict of Interest Statement

The NHS Race and Health Observatory (RHO) is committed to upholding the highest standards of transparency, fairness, and integrity in all our work. We work with a wide range of experts, communities, and stakeholders, many of whom are involved in shaping and delivering our research and commissioning processes.

What is a conflict of interest? 

A conflict of interest occurs when an individual’s personal or professional interests are incompatible with RHO’s impartial and objective decision-making responsibilities of the RHO. This can lead to or appear to lead to undue influence over RHO’s work, decisions, or processes. 

Conflicts of interest may be: 

• Financial – where an individual stands to gain financially from a decision or activity.
• Non-financial personal – where an individual could benefit reputationally or personally from a connection to RHO’s work.
• Professional – where an individual may gain professional advantage through knowledge or access obtained via their involvement with RHO.
• Indirect – where the benefit is not to the individual directly, but to a connected person or organisation, such as a close family member or an organisation in which they hold a significant stake.

Not all external interests give rise to a conflict. A duality of interest may exist, such as through an individual’s participation in another advisory group which does not result in a benefit to them and does not prevent them from acting in the best interest of each organisation. 

Purpose of this statement 

RHO conducts most of its research by commissioning external organisations through competitive tendering. The Invitation to Tender (ITT) process is co-designed with stakeholders, including our internal advisory groups and with meaningful community participation. 

Given this model, all individuals involved in shaping, reviewing, or overseeing research activities, including staff, advisory group members, and external contributors must declare any actual, potential, or perceived conflicts of interest to protect the integrity of the process and to ensure public trust. 

Our policy

RHO is committed to identifying, managing, and mitigating conflicts of interest to uphold transparency, fairness, and ethical practice. 

We require: 

• Full disclosure of any personal or professional interests relevant to RHO activities
• Ongoing updates when circumstances change
• Transparent management of any conflicts, which may include (but not limited to):

  – Restricting access to discussions or documents 

  – Recusal from evaluation or procurement 

  – Removal from advisory or decision-making roles 

Everyone involved with RHO must act in its best interest and maintain confidentiality. 

Where there is a breach of policy 

Where a conflict of interest is not disclosed or improperly managed, RHO reserves the right to take corrective action. This may include: 

• Disqualification of an associated organisation’s bid from the ITT process
• Termination of an individual’s role or contract with RHO
• Other appropriate measures to uphold the integrity of our programmes

Breaches can be reported in the following ways: 

• RHO team and advisory group members may report breaches directly to the Project Lead and/or RHO Programme Committee. 

• Third parties may report breaches by contacting the RHO team via [email protected]. 

The Project Lead and the RHO Programme Committee are responsible for reviewing and managing disclosures. If an individual disagrees with the decision made under this policy, they may request a review by the RHO Senior Leadership Team, whose decision will be final. 

Exceptions 

We acknowledge that some of our research areas are highly specialised, and the available pool of expert contributors is limited. 

For example, a technical expert involved in shaping a research tender may belong to an organisation that later submits a bid. In such exceptional instances: 

• The decision to allow continued involvement will be made by the RHO Programme Committee
• An ethical firewall will be implemented. This means that the expert’s work on RHO activities will be clearly separated, through restricted access to files, records of communications, and explicit instruction that they must not discuss tender design with colleagues involved in bidding.
• The expert will be recused from procurement discussions and not named in the submitting organisation’s proposal

All such decisions will be formally documented and reviewed by the Project Lead and RHO Programme Committee to ensure transparency and accountability. 

Compliance 

All RHO staff, advisory group members, and relevant non-RHO contributors are required to:

• Read and understand our conflict of interest policy
• Complete a declaration form
• Notify us of any changes to their circumstances 

For questions or to request a copy of our full Conflict of Interest Policy, please get in touch with us at [email protected]