Guidance on developing a conflicts of interest policy Published: May 2014 AMRC members are required to have a written policy on how to deal with conflicts of interest in scientific advisory panels. A good policy identifies potential conflicts of interest, and sets out how to record and manage them. AMRC members can have a specific policy for managing conflicts of interest in the scientific advisory panel, or incorporate it into one that covers the codes of practice of their trustees, staff and volunteers. This guidance contains a model policy that members can adapt to their own organisation’s needs and includes case studies of policies used by AMRC members. Model conflicts of interest policy Please feel free to adapt the following model policy to suit the needs of your organisation. 1) General This policy relates to all committees and other funding panels of the charity, their chairs and other members, including trustees of the charity. The purpose of this document is to minimise the potential for conflicts of interest arising and to protect the charity and those who work for it from any perception, real or otherwise, that the external interests and affiliations of its committee members might interfere with their ability to work towards the furtherance of the charity’s. 2) Declaration of interest Any persons covered by this policy, as defined in paragraph 1a), must declare any disclosable external interest on their appointment to the charity, and annually thereafter. A register of interests will be kept up to date by the charity. Interests which should be disclosed by such individuals include: Equity interests (if worth £10,000 or more, or more than 1% of the total issued capital) in enterprises with involvement in pharmaceuticals, healthcare, biotech or related areas, or in any other enterprise that may have a real or perceived interest in the work of the charity. Third party investments (e.g. ISAs) should be held exempt from this. Consultancies and other external appointments (paid and unpaid), together with details of any remuneration or other benefits arising from these. Panel members (including trustees who serve on panels) should also adhere to the spirit of this document and declare any other interests which they feel may be a source of conflict, or which might be perceived to conflict, with the interests of the charity. This includes interests held by the panel members’ spouse or children. 3) Discussion of proposals Details of applications, meeting papers and related correspondence and the names of external referees are strictly confidential and should not be discussed with persons outside the review process. Discussions of a proposal between members of a funding committee which occur outside a committee meeting should be declared to the chair of the committee. If a committee member (including serving trustees) is approached by an applicant for technical advice on an application, he or she may provide advice, but must report this to the committee chair and secretariat. They may subsequently be asked by the chair to absent themselves from a discussion of the application concerned. 3) Managing conflicts of interests Where a panel member is an applicant or co-applicant on a grant application, he or she must declare an interest and withdraw from any consideration of that application. That member will not receive documents pertaining to the application, learn the identity of its referees or receive its referees' reports. He or she must retire from the meeting when the application is assessed. Details of discussion of that application will be deleted from any papers the member receives. This should also apply to trustees who serve as panel members and are applicants in the grant round. Where the chair of the panel is an applicant or co-applicant on a grant application, he or she must declare an interest and should not be involved in that round of meetings. A vice chair will chair the meeting to prevent any undue influence. Panel members who could be seen as a direct competitor of the applicant (e.g. they are funded or applying for funding on a similar project to the proposal under discussion) or have collaborated or published with the proposal applicant within the past three years, or work in the same institution, should declare an interest and may be asked to withdraw from the meeting for that application, or may be allowed to stay, but not vote on the application. 4) Resolution conflicts of interest The Charity recognises that the majority of conflicts or potential conflicts will relate to a particular issue and as such will not present any long term restrictions on an individual’s ability to work for the charity or to sit on its committees. In a small number of cases, major conflicts of interest may arise which compromise an individual’s ability to continue in their position within the charity. Where such a situation relates to a member of a funding committee/panel, the matter will be discussed by the chair of the committee together with a committee staff member or secretary. In cases where agreement cannot be reached through this means, the case will be referred to the committee as a whole, whose decision should be taken as final. Members of funding committees are expected to declare any potential conflicts of interest relating to individual funding decisions to the committee secretariat before the meeting wherein they will be discussed, or during the meeting as soon as the existence of a conflict becomes apparent. In cases where an individual is uncertain as to whether a conflict of interest exists or not, they should report this to the committee secretariat. The secretariat shall discuss the matter with the individual as necessary and report to the Chair, who will decide on a course of action. If an individual is concerned about a possible conflict of interest involving another member of a funding panel, then he or she should raise the matter with the chair of the panel. 5) Updating the policy The charity will endeavour to review this policy, if necessary, every two years, in consultation with the board of Trustees. Case studies: Policies used by member charities Alzheimer’s Society Peer review panel members for the Alzheimer’s Society operate according to a terms of reference and a code of conduct that lays out how panel members should behave, including declaring vested interests. Grant review – Code of conduct The Alzheimer’s Society aims to ensure that research proposals are assessed objectively and impartially. Review by an appropriately constituted group is seen as an essential element of the decision making process. The Board of Trustees relies heavily on the willingness of members of the dementia community to give time to participate in review groups and appreciates their willingness to do so. Members should be aware that the role of reviewers groups is advisory. As part of its commitment to impartiality and the integrity of the review process, the Society has set down the Code of Conduct printed below. If the Society has reason to believe that a member of a review group has breached this Code of Conduct, then he or she may be asked to step down as a reviewer, Board member or Strategic Advisor. Code of conduct As a condition of participation, reviewers agree that documents and correspondence relating to applications for funds and funding are strictly confidential and therefore: Should not be discussed with anyone else during review, or either before or after the Grant Advisory Board meeting. No discussion should occur between Board members except during the business of the Feedback to candidates (successful or unsuccessful) will be provided by the Society alone, to avoid confusion. Grant Advisory Board members should not, under any circumstances, provide feedback directly to the Should not be disseminated Any printouts should be kept secure and disposed of securely after the decision has been reached Should a reviewer have a vested interest (organisational, collaborative, personal or other) in the outcome of a grant application they should declare Reviewers have a right to expect that their comments will be treated in confidence by both the Society’s staff and other members of the review groups Grant applicants will receive anonymised feedback from the reviewers While membership of each Grant Advisory Board will be publicly available, the identity of reviewers in relation to specific grants will be kept Meningitis Research Foundation Code of conduct Code of conduct for scientific advisors, external referees, applicants and Foundation staff Details of research applications and related correspondence, Scientific Advisory Panel meetings papers, and the identity of external referees are strictly confidential and must be kept secure and not disseminated to or discussed with others outside the review process. Panel members and external referees can expect that their comments will be treated in confidence by Foundation staff. Applicants can expect that Foundation staff will not disclose details of their applications to those outside the review process. When we inform applicants of the outcome of their applications, we provide anonymous versions of referees' comments, and may also summarise the conclusion reached by the Panel. Information that might identify the comments of individual Panel members or referees is never revealed. It is our policy to let external referees know the final outcome of applications they have reviewed after we have communicated decisions to applicants. Referees agree to treat all details of applications and their outcomes as confidential. When a Panel member is connected with an application, he or she must declare an interest and withdraw from any consideration of that application. That member does not receive documents pertaining to the application, learn the identity of its referees or receive its referees' reports, and does not score the application. He or she must retire from the meeting when the application is assessed. Details of discussion of that application are expurgated from any papers the member receives. Applicants should not, under any circumstances, directly approach members of the Foundation's Scientific Advisory Panel in connection with their (or another's) research application. Panel members should refuse any requests for information or feedback from applicants on how a particular judgement was reached. The Brain Tumour Charity The Brain Tumour Charity includes a section on conflicts of interest in its document outlining the research grant application process. Conflict of interest BTC makes every effort to ensure that its decisions are fair, objective and transparent. We have conflict of interest policies affecting external and internal reviews, Grant Review and Monitoring committee (GRAM) members and Trustees. Reviewers For both external and internal reviews, a conflict of interest policy is in place to seek to avoid the involvement of individuals with a conflict of interest in relation to an application throughout its review. Individuals who are applicants or co-applicants in the grant round are excluded from acting as external reviewers for any of the applications. GRAM members from the same institution as an applicant will not act as internal reviewers on these applications. When any internal or external individual is invited or assigned to review an application, they are asked to declare whether they have a conflict of interest. Where a potential conflict is declared, they will usually be asked not to undertake the review depending on the nature of the conflict. Such conflicts of interest might include previous collaboration with one of the applicants or co-applicants, being related to an applicant or co-applicant, or financial interests such as shares relevant to the application. GRAM members GRAM members are required to complete a conflict of interest declaration when they become a member of the committee, and annually thereafter, in which they must declare any interests which may potentially cause a conflict in the course of fulfilling their duties and responsibilities as a committee member. No GRAM member with a conflict of interest with a particular application may participate in the review of that application. As a result, GRAM members who have an application under consideration will not receive any of the reviewers’ comments on that application and shall absent themselves from the room when that application is up for review. In cases where the potential for conflict is uncertain, the Chair of the GRAM shall judge whether the individual should be excluded from the discussions. Trustees Trustees are required to complete a conflict of interest declaration annually, in which they must declare any interests which may potentially cause a conflict in the course of fulfilling their duties and responsibilities as a Trustee. Trustees with a conflict of interest shall absent themselves from the room for discussions where the conflict exists. In cases where the potential for conflict is uncertain, the Chair of Trustees shall judge whether the individual should be excluded from the discussions.