Our Code of Ethics

Overview

To support this commitment we have developed a number of guiding principles as a reference point for ethical decision-making.

The guiding principles are part of the Code of Ethics which is designed to provide an overarching guide to ethical conduct.

The code is supplemented by a series of ten questions (PDF) which heads of departments and relevant Professional Services Directors are asked to consider in respect of any new activity or changed circumstances.

These questions are intended to support heads of departments and professional services directors to consider the ethical and reputational risks associated with a given activity.

Guiding Principles

To support this commitment we have developed a number of guiding principles as a reference point for ethical decision making, namely that the University and individual members of staff will:

• Behave with independence, consistency, honesty and transparency in all our activities.
• Carry out research and scholarship of a quality which commands the respect of academic peers, which is open to testing and refutation, and which is undertaken in an ethical and legal manner.
• Defend and promote the freedom to pursue, advance, and disseminate knowledge and ideas.
• Test received wisdom, examine evidence critically, consider and evaluate all opinions, beliefs and arguments with respect.
• Award degrees based on merit.
• Act in accordance with our Charter and Statutes and our Charitable objects

Ethics refer to the standards of behaviour that the University and individual members of staff apply in decision-making and action in the course of their day-to-day activities. Like other sectors, personal and corporate ethics inform and underpin the regulatory and codified regimes applicable to higher education institutions. The Seven Principles of Public Life (the ethical standards expected of holders of public office, including members of university governing bodies) are a useful guide to ethical behaviour: https://www.gov.uk/government/publications/the-7-principles-of-public-life

Ethics 

Personal Ethics

Unethical personal behaviour by an individual is unacceptable. While the law can establish what behaviour is right and wrong, unethical behaviour is also determined by social attitudes of morality and good conduct.

Ethical behaviour helps to build trust, and in the context of the University is associated with individuals acting with integrity and transparency.

Unethical behaviour is commonly associated with selfishness, seeking personal satisfaction and the fulfilment of personal objectives (to the detriment of colleagues, the University itself, or third party individuals or organisations).

Organisational (Corporate) Ethics

Corporate ethics are standards of behaviour expected of the University, which affects its relationships with staff, students and partners, as well as with funders and regulators, the region and society as a whole.

These standards relate primarily to the Code’s guiding principles and support the University Vision and Strategy.

They provide an institutional context within which individual staff can ensure that their personal behaviour is ethical in support of the collective achievement of the University’s strategic and charitable objectives.

Professional Ethics

Many professions, such as medicine, law and other chartered occupations, are governed by professional bodies that require members to act in accordance with certain professional standards, including ethics.

Staff (and students) holding or seeking professional accreditation should also have regard to the standards of conduct expected and required by their respective professional body.

Many of these will be the same or similar to other ‘personal’ ethics and may include principles of independence, confidentiality and selflessness, as well as honesty and integrity.

Data Ethics

Data Ethics guides appropriate and responsible data use in the University by ensuring staff understand the ethical considerations and address these within their processing roles and projects. The four elements of the theme are:

Legality: The University has a legal obligation to obey the law in any data processing or projects. This includes ensuring any processing or project complies with the GDPR and DPA 2018. Data protection by design and by default is a legal requirement under the GDPR (see Article 25). It is a legal obligation under Article 35 of the GDPR to complete a data protection impact assessments (DPIA) when there’s likely to be a risk to people’s rights, particularly when using new technologies. It is good practice to do a DPIA for any use of personal data. new processing or projects will only proceed when relevant legal requirements have been met, compulsory assessments completed and, for projects not covered under the research ethics policy, the Data Protection Officer has been consulted. For research involving processing of personal data, ethical review provides the mechanism for assessment of new projects and approval must be obtained in accordance with the Policy Governing Research Involving Human Participants, Personal Data and Human Tissue before commencing.

GDPR and data protection

Transparency: Where the University processes data it will be open and transparent by publishing information on its website about the data it holds, the processing it undertakes or non-research projects it is undertaking in an easily-accessible format. The University will publish Privacy Notices to provide information to people on, in general terms, what personal information it holds and for what purpose. For individual research projects, appropriate arrangements for providing information to participants/data subjects will be agreed as part of the ethical review in accordance with the Policy Governing Research Involving Human Participants, Personal Data and Human Tissue. The use of data will be appropriate to the consent given by those who provided the data. Where algorithms are used the University will provide an explanation that can be understood in human terms e.g. what variables are used to provide information and how the algorithm came to give an output, and how changing the inputs can change the output.

Privacy notices

Cookie and similar technologies policy

Accountability: The University will maintain effective governance and oversight mechanisms for any data processing or project to ensure effective oversight and control over the processing and the decisions and actions taken as a result. The University will not proceed with processing or projects where the mechanisms for scrutiny, governance, or peer review for the processing or project haven’t been established.

Data protection: Guidance for employees

Fairness: The University will take all reasonable steps to eliminate the potential for any processing or project’s potential to have unintended discriminatory effects on individuals and social groups. Data analysis or automated decision making must not result in outcomes that lead to discrimination as defined in the Equality Act 2010. The University will not proceed with processing or projects where there is a significant risk the processing or project will result in harm or detrimental discriminatory effects for certain groups. If data intended for a processing task or project is of poor quality, unsuitable, unreliable, or not representative then its limitations will be clearly set out, or the processing or project cease.

Equality impact assessments (Staff / PGR login required)

This Code is designed to provide an overarching guide to ethical conduct, with reference to practical application in six broad areas of University activity: education (including student recruitment & admissions, teaching partnerships and awards); research and innovation (including research partnerships); fundraising; finance; and declarations of interest.

Appendix 1 to this Code sets out a series of guiding questions for Heads of Department to use with a relevant Professional Services Director to help evaluate any ethical issues around a particular decision, e.g. associated any reputational risk.

For more details of the kinds of due diligence checks that are or may be required for a particular matter, and contact details for further advice from professional services departments, please refer to the Partnership Due Diligence Framework, and the accompanying case studies and flowchart, which sets out current practice and expectations for different types of activity to supplement the provisions and policies set out in the Code,

Policies and Procedures

The University deliberately does not attempt to set out a pre-determined list of ‘ethical’ or ‘non-ethical’ activities.  Rather, we have established mechanisms by which informed decisions can be taken on matters relating to ethics (and the associated risks) on a case-by-case basis, within the appropriate policy or procedural context.

In the following paragraphs you will find links to the most relevant policies, procedures and guidance in respect of the four broad areas referred to above (some links are only accessible to members of University staff or students and require a log-in).

• education;
• research and innovation;
• fundraising;
• finance;
• declarations of interest.

Also included are points of contact in the case of any further queries.

Education

When considering ethical matters relating to education, including admissions, teaching partnerships, and awards, relevant procedures are the following

Education

Processes and Policies related to Learning and Teaching

Student Admissions Policy

Student Placement Learning Policy and Guidance (PDF)

University Framework for Collaborative Provision

Equality and Diversity Policies and Procedures

Principles of Engaged Learning and Teaching

Guidance for Students on the Use of Unfair Means

Code of Practice on Freedom of Speech and Academic Freedom (PDF)

Student Code of Conduct

Regulations relating to students, including examinations and awards, discipline, and computing (Regulations XVIII - XXIV)

Information Security Policies

Our Commitment (a statement of partnership between students and teachers)

Safeguarding Policy and associated procedures

Honorary Degrees Process and Procedures (including guidance on process and deadlines)

Prevent Duty

Please contact the Student and Academic Services Executive Team if there are questions which cannot be addressed through the policies and procedures set out above.

Research and Innovation

When considering ethical matters concerning research, knowledge exchange and related partnerships, relevant procedures are the following:

Research and Innovation

Policy on Good Research and Innovation Practices (PDF)

Policy on security-related issues in international research collaboration (‘Trusted Research’)

Security Sensitive Research

Guidance on the ethics and integrity challenges of international research collaborations

University Policies and Procedures relating to Research Integrity and Ethics

Guidance on Export Control Legislation

Conflicts of Interest (See Declarations of Interest below)

University Research Misconduct Toolkit

University Research Misconduct Policy (PDF)

Research Misconduct procedure (PDF)

Guidance on Intellectual Property

Spin Out Companies and Licensing

University Research Governance Procedure (relating to health and social care research)

Ethical Policy on Use of Animals in Research

Research Data Management Procedures

Guidance on Collaborative Research

Regulations relating to research students, including examinations and awards, discipline, and computing

Information Security Policies

Heritage Collections Acquisitions

Preventing Harm in Research and Innovation (Safeguarding)

Policy Governing Research Involving Human Participants, Personal Data  and Human Tissue​​​​​​​​

Please contact Research, Partnerships and Innovation if there are questions which cannot be addressed through the policies and procedures set out above.

Fundraising

When considering ethical matters concerning fundraising, gifts and hospitality, relevant procedures are the following:

Fundraising

Charitable Fundraising Information relating to the University

Financial Regulations relating to Donations, Bequests and Legacies; and also Gifts and Hospitality

Fundraising Guide

Donation Acceptance Policy

Policy Statement on Conflicts of Interest (see Declarations of Interest below)

Fraud, Bribery and Whistleblowing Policies

Please contact the Director of Campaigns and Alumni Relations if there are questions which cannot be addressed through the policies and procedures set out above.

Finance

When considering ethical matters concerning finance, relevant procedures are the following:

Finance

Charitable Governance Information

Financial Regulations

Endowment Investment Policy (PDF)

Statement on Sustainable Procurement

University Financial Control and Governance arrangements, including the role of Audit Committee and Serious Incident Reporting

Policies relating to compliance with the Payment Card Industry Data Security Standard

Conflicts of Interest (see Declarations of Interest below)

Terms and conditions for supply of goods and services

Fraud, Bribery and Whistleblowing Policies

Guidance on the application of financial and trade sanctions (PDF)

Guidance on Facilitation Payments and the Bribery Act (PDF)

Financial regulations for subsidiary companies

Policy for the Creation, Disposal and Governance of University (subsidiary) Companies

Please contact the Chief Financial Officer or Director of Finance if there are questions which cannot be addressed through the policies and procedures set out above.

Declarations of Interest 

When considering the existence of any actual or potential conflicts of interest, and how these should be declared and managed in a given situation, relevant procedures are the following:

Declarations of Interest

Conflicts of Interest Homepage (including information for HoDs)

Conflicts of Interest in Decision Making Procedure (PDF)

Personal Relationships Policy

Good Practice for handling conflicts of interest in research

Conflicts of interest in postgraduate supervision

Finance: Financial Regulation 25

Financial Regulations Supplementary Information Appendices

Financial Conflict of Interest Policy for US Public Health Service funded research

Training

Please contact the University Secretary in the first instance if there are questions which cannot be addressed through the policies and procedures set out above.

Publication, Monitoring, Reporting and Review

This Code of Ethics was first approved in July 2017. The Code will continue to be publicised within the University and will be available on the University website.  It will be drawn to the attention of new members of staff and new heads of department.

The Code is supplemented by a series of ten questions which Heads of Departments and relevant Professional Services Directors are asked to consider in respect of any new activity or changed circumstances. These questions are intended to support HoDs and Professional Services Directors to consider the ethical and reputational risks associated with a given activity.

Breaches of relevant policy and procedures may result in disciplinary action. 

The University's Fraud, Bribery and Whistleblowing Policies provides a means for any individual to raise matters of concern as regards malpractice, impropriety or wrongdoing.

The policies and procedures referred to in section B above are subject to monitoring, reporting and review by those responsible for oversight in each case. By way of example, regular reports on matters regarding teaching partnerships are made by the Committee for Collaborative Provision to the Learning and Teaching Committee of the Senate; the Research Ethics Committee reports regularly on its work to the Senate; the Honorary Degrees Committee reports on its deliberations during each academic year to the Senate and to the Council. The University Secretary has responsibility for ethical matters and effective operation of the University’s framework for decision making on ethical matters.

Alongside these specific reporting arrangements, the University Executive Board will review the operation of this overarching Code, including ensuring that the various related policies, procedures and guidelines are current, publicised, and operating, and will report to Council, via its Audit Committee.