Conflict of interest policy

The Ada Lovelace Institute was created to be a trusted voice in public discussion on data and AI, independent of government and sectoral interests. To hold this position, it must maintain visible independence in all its work, while interacting with government, industry and other relevant stakeholders.

The Ada Oversight Board is made up of a balanced range of views and perspectives, and its authority will depend on its having experience and credibility in those circles, while maintaining independence.

All Ada Oversight Board members are appointed because of their professional experience and knowledge, which they will use to contribute to Ada’s strategic decision-making.

Regardless of their employment or institutional affiliation, they are appointed as individuals. They do not represent, and should not seek to represent, the institutional views of any stakeholder with which they may be associated.

Types of conflict of interest

Relevant experience can also give rise to conflicts of interest, which present a reputational risk to Ada and underscore the need for transparency and proper process. Anyone who holds a formal role with the Institute must understand and adhere strictly to this conflict of interest policy.

Conflicts may consist of any interests that create a real or perceived incentive for an individual to act outside the best interests of the Institute. These incentives may include personal, institutional, financial, career and other considerations. For example, conflict of interest may arise from discussions on partnership with an organisation where the Oversight Board member has an interest.

There may also be perceived conflicts of interest. This is where a reasonable onlooker could perceive that an individual has an undue interest in a discussion or decision, even if this perception is untrue. For example, the publication of an Ada report that deals directly with the policies and actions of an institution of which an Ada Oversight Board member may be involved.

Declaring conflicts of interest

As soon as an Oversight Board member is aware of a potential conflict, they should report it to the Chair and Director. If the Chair or Director becomes aware of a potential conflict for an Oversight Board member arising from a forthcoming piece of work, they should raise it with the member. Attendees at meetings are required to declare in advance any conflicts of interest in relation to the business of the meeting to the Chair, unless these have previously been declared and appear on the Register of Interests. Any other conflicts of interest should be reported to the Chair and Director as they arise.

It is the responsibility of individuals with conflicts to:

• notify possible conflict to the Chair or Director in advance of any relevant discussion
• if in doubt, err on the side of mentioning possible conflicts
• agree with the Chair what part, if any, the individual should take in discussion or decision of the relevant matter
• not to seek to enquire into or influence any decision on which the individual is in conflict.

Considerations for formal appointments

As part of the selection process for any role, the interview panel will review conflicts of interest. Particular attention is paid to:

• any specific conflicts which we may expect to arise from that interviewee’s particular interests, and how they may be managed
• to what extent the interviewee shows awareness of potential conflicts and has realistic ability to mitigate them
• whether the interviewee can demonstrate their ability to act as an independent from their other interests, and to act in the Institute’s best interests during their tenure
• whether appointing this Oversight Board member would allow us to maintain a balanced set of perspectives across the Oversight Board as a whole

There are cases where the conflict of interest is not realistically possible to mitigate. For example, if a potential  Oversight Board member’s main employment requires them to advocate publicly for the interests and position of their employer. In these cases, the prospective Oversight Board member will not be appointed.

Register of Interests

Ada keeps a register of the appointments held by individuals who represent the Institute and which could give rise to conflicts of interest.

Examples of appointments which should be included on the register are:

• any Trusteeship or Directorship
• principal employer and any significant subsidiary employers
• organisations in which the Oversight Board member holds financial investments of £25,000 and above or has more than 1% ownership
• any other significant positions or associations in bodies relevant to Ada’s interests.

These disclosure rules also apply to close family members of the individuals concerned, if there is any possibility of conflict.

Any such interests should be declared on the Register of Interests when they first arise, and changes will be reviewed at each Oversight Board meeting. Any change to interests, including from external events such as a corporate change of control, should be recorded.

The Director is responsible for the management and keeping of the register. The register, including a history of changes, will be maintained and stored electronically.

Mitigating conflicts of interest

The Chair will decide on appropriate mitigation actions or procedures for any conflict of interest.

This may include requiring an individual to abstain from giving input on a matter, to leave an Oversight Board meeting, or to not receive certain papers.

There are occasions where an individual with a conflict of interest can nonetheless provide valuable perspective and insight. In these cases, the Chair will ensure that these perspectives are set in an appropriate wider context, and that the individual in conflict is not put in a position where they are unable to act in the Institute’s best interests.

External communications

As an independent organisation, it is important that we don’t unintentionally create perceived connections with other organisations. Therefore, other institutions should not make use of an Oversight Board member or adviser’s Ada affiliation in their public communications, without seeking prior approval from the Director.

On occasion, Ada’s public communications or research will relate to an Oversight Board member’s other interests. In these situations, the individual will not be permitted to influence the strategic direction or content of these communications or research.

If commenting publicly on matters relevant to Ada, individuals should make clear whether they are speaking in an Ada capacity or with another affiliation, and should be mindful of the potential impact of any public comments on perceptions of Ada. If there is any doubt about the substance or appropriateness of communications, Ada’s Communications team is available to support and advise on the representation of Ada and our research.

Compliance with this policy

Oversight Board members must comply with this policy at all times and agree to be governed by the Code of Conduct. If it becomes impossible to comply with this policy, for example because of actions of other institutions in which they have a competing interest, individuals may be asked to step down.