ices conflict of interest policy, Schemes and Mind Maps of Business

Download ices conflict of interest policy and more Schemes and Mind Maps Business in PDF only on Docsity! rev. Oct 19, 2015 Page 1 of 6 ICES CONFLICT OF INTEREST POLICY Frequently asked questions 1. Conflicts of interest are any situations where there is a potential divergence between an individual’s private interests and his or her obligations to ICES. What does “obligations to ICES” mean? All those in the ICES community have obligations to ICES, which is defined by the work they do under the auspices of the institution. ICES is a publicly funded, not-for-profit organization that has a mission of research excellence resulting in trusted evidence that makes policy better, health care stronger and people healthier. To meet its mandate, ICES must produce, and be perceived as producing trusted and excellent research that is in the public’s best interest and it must protect its reputation to ensure continued public trust. ICES’ reputation is dependent on it. The work done under the auspices of the institution by those in the ICES community must reflect ICES’ mission. Therefore, one’s obligations to ICES are broadly defined and includes ICES’ mandate to ensure the public’s best interest and ensure continued public trust. ICES mission and reputation includes the work you do under its auspices. When reviewing conflict of interest declarations, the CEO will consider, among other things, whether a potential or actual conflict of interest situation relates directly (or be reasonably seen to relate directly) to the individual’s ICES research or research program. See the definition of Conflict of Interest for other considerations. All members of the ICES community must make fulsome declarations and the CEO will determine if it is a conflict of interest or not, taking into consideration the individual’s ICES research or research program as well as the other considerations. 2. The Policy says that I can consult or act in an advisory capacity to a for-profit company or agency if there is a fixed term contract, if it is not otherwise prohibited, and if the work is independent to ICES, does not use ICES data, name, logo, or business tools and does not compromise (or be seen to reasonably compromise) ICES reputation or mission. I have to declare the activity and it is possible a Management Plan may be needed. What does “compromise ICES reputation or mission” mean here? What is a “fixed term contract”? rev. Oct 19, 2015 Page 2 of 6 Conflict of interest is any situation where there is a potential divergence between someone’s private interests and his or her obligations to ICES. As stated in F & Q #1, one’s obligation to ICES includes the work one does under the auspices of ICES. Therefore, if the private interest (individual financial interest or benefit or family financial interest or benefit) is directly related to one’s ICES research this could make the activity prohibited. In terms of ICES’ mission or reputation, if the consulting or advisory work negatively impacts on ICES being able to produce trusted and excellent research that is in the public’s best interest and maintain continued public trust it would make the activity prohibited. If the activity is not directly related to one’s ICES research, the CEO will consider, among other things, the amount of money received as that could impact of ICES’ reputation (e.g., over 10k). A fixed term contract is one that sets out expectations for each of the parties with a termination date (with no further obligations) and requires signatures. This contract must be submitted to ICES with your COI Declaration Form. ICES will review the agreement to ensure it is independent to ICES, and, among other things, does not involved ICES data, name, logo or business tools. ICES will need to review the nature of the work to satisfy itself the service provided is not in conflict with your research and does not compromise (or be perceived to compromise) ICES reputation and mission. Particularly if there are more than one fixed term contract (regardless of whether it is with the same entity or not), ICES will consider the total annual remuneration as well. 3. I directly hold stock or stock options (i.e. not as part of a mutual fund) in a number of companies, but they are not biomedical in nature or otherwise related to my ICES research or research program or the work of ICES. Should I still declare them? As per that definition, you have to declare stock and stock options if it impacts on your obligations to ICES (see F & Q #1) or if it could directly affect (or reasonably be perceived to affect) ICES mission or reputation (see F & Q #2), ICES core business, an ICES action, or the research question, design, conduct, analysis or reporting of a study. However, sometimes it is difficult to determine whether there is a conflict of interest and therefore you will want to err on the side of caution and seek consultation from your manager or CEO or disclose it on your declaration form. 4. I directly hold stock or stock options (i.e. not as part of a mutual fund) in a number of companies, some that are biomedical in nature (e.g., device company, pharmaceutical rev. Oct 19, 2015 Page 5 of 6 annual declaration should include any previously declared conflicts of interest that are still relevant, as well as any new ones. The ad hoc declaration only needs to include information about the new conflicts of interest situations. Those individuals being considered for an appointment must declare any conflicts of interest for the past 3 years, and then if the appointment is granted, annually and on an ad hoc basis. 11. I am on advisory committees and I am a consultant for various non-profit organizations that are health related. Do I need to declare these given that they are not for profit? Yes, if it creates an Individual Financial Interest or Benefit or a Family Financial Interest or Benefit. The issue is not whether the organization is for profit or not, but rather one’s private interests. 12. I receive financial benefits from several pharmaceutical companies. I think this reduces my conflict of interest situation because I have a relationship with several such companies rather than with just one. Is this taken into consideration when my conflict of interest declaration is reviewed? Regardless of whether you receive a financial benefit from one, several or many pharmaceutical companies, there could be a conflicts of interest situations because of the work you do under the auspices of ICES and because of ICES’ reputation or mission. Receiving a financial benefit from one, as opposed to several pharmaceutical companies does not increase or decrease the conflict of interest situation as it is situation specific (i.e. depends on the work that you do under the auspices of ICES and ICES’ reputation and mission). The ICES COI policy says it is prohibited to conduct research with, or for, another entity without ICES approval which uses ICES data, name, logo or business tools. Research that is funded in whole or in part by industry or other non-public source may be permissible only if certain conditions are met. Given the wide variation in circumstances for such funding, each must be reviewed for approval by the ICES CEO on a case-by-case basis. Contact the CEO’s office for further detail. rev. Oct 19, 2015 Page 6 of 6 13. What do I do if I’m not sure about the need to declare an actual, perceived or potential conflict of interest situation? Since it is the responsibility of all those in the ICES community to make a full and accurate disclosure of actual, perceived and potential conflicts of interest situations, individuals should err on the side of caution and make the disclosure. Any questions or ambiguities can be brought to the attention of the CEO. I have been asked to give talks or presentations that are related to my clinical and/or research work and is sponsored by a third party (e.g. Private company). Would this be considered an actual or potential conflict of interest by ICES? There are several factors that ICES considers in determining whether these talks or presentations sponsored by a third party sponsor represent an actual, potential or perceived COI. First, ICES scientists should have full academic control over the content of their talks/presentations (i.e. They create the content and do not use slides provided by a third party, the sponsor/third party does not have the authority to approve your presentation or require changes, and you approve the final version of the talk before presentation). Second, ICES will consider the total number of talks/presentations sponsored by a third party and the related total honoraria in judging whether there is a COI. Third, there should be a contract signed for talks/presentations and ICES may request to review it. Formal membership in a speaker’s bureau where you do not exercise academic control of talks is considered a COI. Even if these conditions about talks/presentations are met it may still be a COI if these particular features are not transparent to ICES or the audience and/or if ICES determines it otherwise compromises or could compromise the public’s trust in ICES. If in doubt, ICES scientists can ask before committing to the talk/presentation, if it might be considered by ICES as a COI.