This obligation applies to all activities at the University, including research and education as well as administration and decision making.
You can find more information on corruption, conflict of interest and bribery in the University's policy against corruption. There you will also find more examples of what situations you should avoid and what can typically be accepted.
If you suspect, or have information about wrongdoings the University would like you to report it. No investigations or measures can be taken against wrongdoings until the University has been made aware of them. Find more information about the Whistleblowing Act.
Corruption
Corruption means that you act in a certain way to colleft benefits for yourself, or someone else. Corruption can, among other things, include:
- taking or offering bribes,
- participating in handling or deciding in a matter where you have a conflict of interest,
- unduly trying to influence a decision,
- upholding a compromising secondary employment,
- benefitting yourself or others at the expense of the employer,
- theft, fraud or embezzle against the employer.
Read more about preventing and combating corruption on the page about basic values at Umeå University.
Conflict of interest and inappropriate actions
You can find the regulation concerning conflict of interest in the Swedish Administrative Procedure Act. These rules clarify when an employee or elected representative can be deemed to have an interest in a matter that calls into question their impartiality. The purpose of these rules are to guarantee objectivity and impartiality and to ensure the public's confidence to the handling of official matters and decision making.
It is not necessary for an official to be biased for a situation to be deemed as involving conflict of interest; it is sufficient for the situation to be such that it might give rise to a suspicion of bias.
No one with a conflict of interest in a matter may decide on or participate in the administration of the matter in question. Anyone who is aware that they have a potential conflict of interest is therefore dutybound to immediately inform the University, for example their immediate manager.
The duty to inform your immediate manager about a conflict of interest lies on you. You are also obliged to refrain from handling the matter on your own volition. You must, for example, refrain from handling the case, being an external expert, taking notes or deciding in the matter. If you have a conflict of interest you must also leave the room when the decision is made. You are, as a rule, allowed to implement a decision made by someone else even if you would have a conflict of interest in the matter. If any circumstance arises during the handling of a case that means that you have a conflict of interest, you must immediately inform your manager about this.
Examples of conflict of interests;
- you have an interest in the matter that your impartiality can be questioned,
- you are related, friend or enemy to a party in the matter,
- you have an economic interest in the matter,
- you are, in any other way, involved in such a way that suspicion may arise that your assessment lacks in impartiality.
The corresponding situations may also cause inappropriate conflicts of interest in research activities and other situations that are not defined as case handling or decision making but that might affect the public's confidence in the University's activities and the result of research.
Examples of situations that should be avoided
Below you will find examples of situations that might constitute conflict of interest or are deemed inappropriate when you deal with official matters and therefore should be avoided. Whether the situation should be considered conflict of interest or otherwise inappropriate is a matter of judgement and depends a lot on the context – for example, where you work and what duties you have. Please, contact the Legal Affair's Office if you need advice on how your situation should be assessed.
Administration and governance
- You participate in a public procurement at the same time as you are the official signatory or owner of a potential bidder.
- You sign an agreement between the University and a company where your partner is a owner.
Recruitment
- You are a member of an employment committee and have co-authored a large number of publications in recent years with one of the applicants for the position. If, on the other hand, a long time has passed since the collaboration, it can be judged that you are no longer disqualified.
- You are a manager, and your spouse is one of the applicants to the position.
- You participate in a recruitment process and your child's partner is one of the applicants.
- You are close friend, or enemy, to an applicant in a recruitment where you are an external expert.
Research
- You are the supervisor of a doctoral student who has assignments in a company in which you are a partner.
- You are the supervisor of a doctoral student who is employed in a company from which you receive research funding.
- You are a board member of a company that you collaborate with in your research project.
Teaching
- You are an examiner for a student from whom you have received financial compensation for private teaching.
- You are the examiner for a student with whom you have or have had a sexual relationship.
- You are a member of a decision-making body for research and education issues that discusses the possible use of a teaching material as mandatory literature in a course and you are the author of and receive compensation for the teaching material.
Compromising secondary employments
Secondary employments, such as having assignments in a company or an organization, are generally allowed. But if the secondary employment is considered to be compromising to the University, it is not allowed. Situations where your secondary employment means that your impartiality or objectivity can be questioned typically means that the secondary employment is compromising.
A typical situation is that you are partner in a company that delivers a product or service to the University. Business transactions between the University and employees' companies should therefore be avoided. If it is necessary for the University to purchase goods or services from an employee's company, this must be approved by the University Director in advance.
Also commitments that does not involve financial compensation can be deemed as a compromising secondary employment. For example, your impartiality may be questioned if you are the president of a non-profit organisation that pursues a controversial issue that has implications on your field of research. On the pages about secondary employment you can read more about how secondary employments should be reported. There you will also find a memo that describes more about how secondary employments are assessed.
Bribery
It is a criminal offence to give or receive bribes. A bribe is a benefit offered in connection to your employment if the benefit objectively risks affecting the recipient in the performance of their duties. What constitutes a bribe depends on the circumstances of the individual case rather than the nature or value of the benefit. Accepting gifts and benefits at all from individuals or companies with whom you are in contact with within official matters entails a risk of bribery. If you are unsure whether an offer may involve a bribe, you should decline what is offered.
Below are a few questions you should ask yourself when offered benefits by external parties. These can assist you in determining whether or not the offer is appropriate.
- Why am I being offered this benefit? If the benefit is linked to the performance of your duties, it should be refused.
- Does the benefit have a high value or is it offered frequently? If the benefit is of significant value, or it is offered frequently, it should be refused.
- Does the benefit have an operational use? If the answer is yes, it should be paid for by the public authority; if the answer is no, the offer should be refused.
- If I accept this offer, is there a risk that it will affect my work? If the answer is yes, the offer should be refused.
- If I accept this offer, is there a risk that public confidence in the University will be undermined? Here, a general risk assessment must be conducted. It is sufficient that a risk of such damage exists for the offer to be refused.
Examples of prohibited undue benefits
- Gifts before or after an examination or decision.
- Cash, gift cards, stocks, shares, bonds, etc.
- Loans at interest below market rates
- Side deliveries of goods or services from the employer's suppliers, such as building materials, transport, services of tradespeople, office supplies, etc
- Private use of vehicles, boats, holiday homes or other accommodation.
- Partial or full payment of pleasure trips or holidays.
- Bonuses earned when travelling on business, such as air miles, free tickets, free hotel nights and similar that accrue to and are used privately by the employee rather than the employer.