The University of Montenegro (UoM) lacks a comprehensive system for identifying, disclosing, assessing and managing conflicts of interest, which means that relationships that may affect the impartiality of recruitment, promotion and decision-making often remain outside institutional oversight. The problem is not only that certain situations are not prohibited, but also that UoM lacks mechanisms for determining whether they are problematic. This is one of the key findings of the analysis by the Centre for Civic Education (CCE), “When Rules Are Silent on Conflicts of Interest – Normative Gaps at UoM, Comparative Analysis and Recommendations for Academic Integrity”, authored by Jovana Radulović, Ivan Kašćelan and Oscar Berisha.
Throughout 2026, CCE pointed to shortcomings in UoM’s normative framework in this area and, in January, submitted an initiative for its improvement, accompanied by concrete recommendations. UoM did not respond to the initiative, while the new Statute, adopted in June 2026, missed the opportunity to address these gaps. Instead, the provisions concerning conflicts of interest remained almost identical to those contained in the 2015 Statute. The current Statute refers to conflicts of interest in only a few provisions, primarily as possible grounds for dismissing a member of the Governing Board, the Rector, or a Dean or Director. However, it neither defines conflicts of interest or related persons, nor prescribes an obligation to disclose conflicts of interest, a procedure for assessing them, or rules on recusal from decision-making. Even the restriction concerning family relationships applies only to reviewers in procedures for appointment to academic titles, while it does not extend to members of committees, councils or the Senate who participate in the same decision-making process.
Therefore, the analysis focuses on the distinction between “not prohibited” and “not problematic”. In UoM practice, the absence of an explicit prohibition often becomes an argument that no problem exists, rather than a reason to assess the risk to impartiality. However, a normative gap is not evidence that a conflict of interest does not exist; it merely allows potentially problematic relationships to remain undisclosed, unassessed and without an institutional response.
Through concrete cases, the analysis demonstrates how risky such an approach can be. Situations have been recorded involving the simultaneous performance of teaching, student and managerial roles, the engagement and joint decision-making of persons related by family ties, as well as decisions on the academic promotion of employees by persons with whom they are involved in ongoing court proceedings. This issue has gained particular significance following the adoption of the new UoM Statute, under which failure to be appointed to a higher academic title may, under certain conditions, also result in termination of employment. When a decision determines not only academic promotion but may also affect employment status, standards of impartiality and safeguards against conflicts of interest must be even stricter – yet such safeguards are lacking at UoM. At the same time, family, professional or other connections do not in themselves automatically imply illegality or bias. However, without an obligation to disclose such relationships, institutional assessment and recusal where necessary, there can be no guarantee that procedures are protected from actual, potential or perceived conflicts of interest.
The analysis also points to a gap between the European standards formally endorsed by UoM and their implementation in practice. UoM has adopted the HRS4R framework and the OTM-R policy, and in 2020 it was awarded the European Commission’s HR Excellence in Research recognition. Nevertheless, these standards have not been translated into concrete procedures for managing conflicts of interest, as there are no mandatory declarations of conflicts of interest for committee members, no clear procedures for disclosure and recusal, and no systematic monitoring of their implementation. The formal existence of regulations and European labels cannot substitute for mechanisms that ensure impartiality in specific procedures.
The comparative analysis shows the extent to which UoM lags behind practices at other universities. For example, the University of Ljubljana requires employees to disclose circumstances that may constitute a conflict of interest and provides for risk-management plans; the University of Belgrade broadly defines related persons, including those connected through family, partnership, godparent, friendship and other personal ties; while the University of Zagreb recognises even antagonism as a potential source of bias. European universities, including the University of Cambridge, the London School of Economics and Political Science (LSE), Charles University, Jagiellonian University, the University of Southampton, City St George’s, University of London, and the University of Rijeka, additionally use written conflict-of-interest declarations, recusal from decision-making, external committee members, registers of disclosed conflicts and monitoring of the implementation of relevant rules. What more developed systems have in common is a simple principle: conflicts of interest are not left unaddressed until they result in a disputed decision; instead, they are managed before such a situation arises.
CCE therefore recommends that, as a first step, UoM adopt a separate Rulebook on the Prevention and Management of Conflicts of Interest, which would define actual, potential and perceived conflicts of interest, as well as the categories of related persons and relationships. The Rulebook should introduce mandatory written conflict-of-interest declarations for members of committees and other decision-making bodies, clear recusal procedures, restrictions on incompatible roles, a central register of disclosed conflicts of interest, and accountability for failure to disclose a conflict or for violations of recusal rules. In parallel, the Statute, Code of Ethics, OTM-R policy and other internal acts should be harmonised, while risk-management plans should be introduced across all organisational units, together with training for employees and committee members, a confidential mechanism for reporting irregularities, and regular monitoring that would demonstrate not only that the rules exist, but that they are actually being implemented.
The aim is not to create additional bureaucracy at UoM, but to establish a system in which impartiality is not assumed, but demonstrated through clear and verifiable rules. Academic autonomy does not mean autonomy from accountability. On the contrary, clear conflict-of-interest rules protect the University from nepotism, favouritism, private interests and suspicions that academic decisions are based on connections rather than merit.
CCE calls on the UoM leadership to translate the recommendations from the analysis into binding rules and procedures. A university that invokes European standards must apply them where they matter most – in decisions on who is recruited, who is promoted, who manages and who makes decisions affecting others. Otherwise, as long as conflict-of-interest rules remain silent, the door remains wide open to doubts about impartiality, as well as to harmful practices.
Milica Borozan, Project Assistant