Introduction

Clear and effective management of conflicts of interest is fundamental to maintaining public trust. It plays a large part in ensuring the integrity of our institutions, and this applies equally to those who work in evaluation, market research, and social research. Chapter 5.6 of the National Statement on Ethical Conduct in Human Research 2025 sets out comprehensive requirements for the disclosure and management of conflicts of interest both in the design and delivery of projects as well as in the ethical review process. This resource explores the meaning of conflicts of interest, the responsibilities of researchers and evaluators, and practical steps for identifying, avoiding, and managing conflicts in these research domains, including how Iris Ethics manages conflicts of interest.

Conflicts of interest

Conflicts of interest arise when professional judgment or actions regarding a primary interest such as participant welfare or impartial analysis are, or could reasonably be perceived to be, unduly influenced by secondary interests. In the context of the National Statement, we can also consider this to include the influence of secondary interests on the capacity of the researcher/evaluator to align with the principles of ethical conduct set out in Section 1. 

Secondary interests may be financial, personal, familial, professional, or organisational. In evaluation, market research, and social research, conflicts of interest can emerge in a variety of ways, both real and perceived. These often arise through connections to sponsors, personal or professional relationships, vested interests in specific outcomes, or overlapping roles.

Real conflicts of interest most commonly occur, for example, when a researcher or evaluator is funded by an organisation with a direct stake in the research results. For example, a market researcher commissioned by a consumer goods company to study attitudes toward a new product may be incentivised, consciously or unconsciously, to present results favourably. Another scenario involves a program manager in the role of evaluating their own program, who may stand to gain professionally (and in the case of grant-funded programs, financially) from positive findings.

Perceived conflicts of interest, while not always involving direct benefits, have the potential to be equally damaging to trust and integrity if not managed appropriately. For instance, a social researcher who previously worked for an organisation now under study may be viewed as partial, even if they act impartially. Similarly, when an evaluator is closely associated with a member of the team being evaluated (perhaps as a former supervisor or collaborator) stakeholders might reasonably question the objectivity of their judgments.

Other common scenarios include:

• Family or close personal relationships with research participants or key stakeholders in the study.
• Simultaneous involvement in competing projects, such as conducting evaluation for two rival organisations.
• Consulting for a client while also collecting data for research that could affect the client’s interests.
• Accepting gifts, hospitality, or benefits from organisations or individuals with an interest in the research outcomes.
• Using privileged information obtained through research for personal gain or to benefit another party.

In each of these cases, whether the conflict is real or only perceived, the potential for undue influence on professional judgment exists. For this reason, careful identification, disclosure, and management of such conflicts are essential to uphold the integrity of research and maintain public confidence in its outcomes.

It is worth noting that, like most risks, conflicts of interest are something that cannot usually be eliminated. The above examples of the commissioned researcher and program manager as program evaluator are incredibly common and almost impossible to avoid in practice. The conflict exists, but what is important is understanding the nature of the interest and taking action to manage it (such as having some degree of independent oversight in the process). It’s also a key reason why professional organisations such as The Research Society and the Australian Evaluation Society have in place codes of conduct for members. These codes of conduct set out how members can ensure impartiality even where there are conflicts of interest.

Conflicts of interest as defined in the National Statement

The National Statement defines a conflict of interest as a situation where: 

“an independent observer might reasonably conclude that the professional actions of a person are or may be unduly influenced by other interests.” 

Importantly, the Statement recognises that the existence of multiple interests does not automatically equate to a conflict, nor does a conflict imply any misconduct. Failure to properly identify or manage conflicts can erode institutional credibility and diminish community trust, and so the focus of the National Statement is on how evaluators, researchers, institutions, and review bodies can effectively manage such interests.

Firstly, researchers, ethics review bodies, and institutions must actively disclose any interests that may relate to proposed or ongoing research. Ethics review bodies like Iris Ethics must also manage interests among both committee members and staff. The identification and disclosure of interests is not limited to financial matters but extends to any situation where secondary interests could influence, or be seen to influence, impartial judgment and decision-making. The responsibilities also include maintaining transparent records and adopting strategies tailored to the specific circumstances of each case.

How we manage conflicts of interest

As an independent Human Research Ethics Committee (HREC), Iris Ethics has a clearly articulated policy for the management of conflicts of interest that forms part of its Standard Operating Procedures. Management of each conflict is undertaken on a case by case basis, as the right level of action required is going to differ based on the nature of the interest, the degree of risk, and the practicality of actions that can be taken.

Disclosure by HREC Members and staff: 

Any committee member with a real or perceived interest that may impact on their ability to act impartially in their duties must declare this at the earliest opportunity to the Managing Director and Chair. Declared interests are maintained in a register and monitored by the Managing Director and Secretariat.

When an application is lodged, the Secretariat considers the register as part of the process of matching the right group of panel members to the application. That way we balance selection of an expert panel with the minimisation of conflicts of interest. For example, if a committee member works for an applicant organisation, in almost all cases that member will be excluded from consideration for the panel and have no access to the application or the deliberations of panel members. In addition, when a panel member is selected, they are required to review and update the register to ensure that new interests are considered.

In the rare case where a conflict still exists in relation to a panel member on an application, the member with an interest will withdraw from discussion and decision-making until deliberations are complete and will not vote on the matter. These actions and absences are recorded. 

Conflict of interest management also extends to all staff of Iris Ethics, who are also required to report conflicts of interest on the register. If an interest is identified that could influence the actions of that staff member, actions are identified by the Managing Director and Chair as appropriate. This may include recusal from roles or access to materials, delegation of decision making, or in extreme cases, relinquishment of financial interest. 

Disclosure by Applicants: 

Applicants must disclose any real or perceived interest, financial or otherwise, that could constitute a conflict with their application. This includes involvement in competing research or evaluation projects. This disclosure is done as part of the application process. Upon identification, the HREC may require management strategies such as:

• Disclosing the interest to research/evaluation participants in recruitment and consent materials
• Disclosure in presentations or publications of findings (a great idea is to have a slide or paragraph by default in your reporting templates)
• Recusal of team members from relevant project decisions
• Modification of roles (e.g., not recruiting or collecting data from participants)
• Inclusion of independent oversight such as peer review, or in the case of an organisation delivering many projects, random auditing of projects
• Relinquishment of financial or other interests by team members
• Withdrawal of the team members from the research/evaluation entirely
• In rare cases, determining the research/evaluation should not be conducted

The last circumstance is extremely rare and is always considered in the context of the principles of the National Statement and whether choosing not to conduct the research/evaluation would result in a disbenefit to stakeholders that outweighs the risks of a conflict of interest. 

That’s why the examples we discussed earlier often still proceed – even if there is a real conflict of interest like having a program manager evaluate their own program, the benefit of having the evaluation conducted to stakeholders is greater than the risk of bias that may arise, especially if the conflict is acknowledged explicitly. Similarly, a commissioned research firm inherently has a financial relationship with clients and that can’t be avoided, and the most common alternatives are either less beneficial (such as not conducting any research at all), or may pose equal or larger conflicts (the company doing its research in-house). 

Practical actions you can take

Managing conflicts of interest is something that should be an ongoing activity for researchers and evaluators. A proactive approach helps to manage risks in projects and can also support ethical review and delivery. Employing strategies like the above as part of the design of your projects helps to identify and manage interests, as well as support ethical review processes.

We recommend that project managers as part of their work employ several key actions:

• Comprehensive Disclosure: Promptly declaring all relevant interests and ensure these are recorded and reviewed.
• Transparent Processes: Keeping accessible records of disclosures and management strategies.
• Tailored Management: Applying conflict management measures suitable to the individual circumstances, such as recusal, replacement, or oversight by an independent party.
• Ongoing Monitoring: Updating disclosures regularly as circumstances evolve during the research or review process.
• Education and Training: Providing regular training for team members on identifying and managing conflicts of interest.

Summary 

Conflicts of interest are an inherent part of evaluation, market research, and social research. The National Statement provides a comprehensive framework for ensuring these conflicts are disclosed, managed, and recorded, upholding both ethical standards and public trust. By fostering transparency, accountability, and proactive management, you can ensure the credibility and ethical conduct of research and evaluation.

Of course, there are some scenarios that may not be covered by our guidance or that provided in the National Statement. It’s one of the reasons we developed the Expert Determination. If you find yourself facing such a scenario, reach out to us and we can advise on the best course of action.