Questions and answers
I. How can Scientific Directors, members of Governing Council and Advisory Bodies prevent and manage conflicts of interest?Footnote 1
1. What is a Conflict of Interest?
A conflict of interest (COI) is a situation in which your external interests or engagements compete or conflict with your official responsibilities to CIHR, and could be seen as furthering your interests (or the interests of your relatives or friends), or giving an unfair advantage to you or to others when dealing with CIHR or the Government of Canada.
A conflict in this context should be interpreted broadly to include any circumstances that could reasonably be perceived as giving rise to COI situations and can be actual, potential or perceived in nature (Section 3 Definitions).
2. What external interests and engagements should I declare?
External interests Include personal interests (such as financial, intellectual, professional, familial), as well as external duties and responsibilities acquired by virtue of employment, membership or other affiliations. The latter may create situations of conflicts of commitments (competing responsibilities) which, if not resolved, may lead to conflict of interest situations.
3. How do I recognize a conflict of interest situation?
Prior to commencing CIHR activities, examine your external interests and engagements by asking yourself the following questions:
- Do I have a particular interest in an external entity or activity which may subject me to demands that are incompatible with my role within CIHR, and may impair (or be seen as impairing) my ability to perform my duties for CIHR in an impartial manner?
- Could my external commitments make me (or be seen as making me):
- knowingly take advantage of (or benefit from) the position I hold or the information that I obtain in the course of my official duties for CIHR, and that is not generally available to the public?
- assist entities or individuals in their dealings with CIHR or the government where this would result in preferential treatment of the entities or individuals, or interfere in the dealings between the two so as to inappropriately influence the outcome?
When in doubt about the existence of a conflict, a declaration is required (Section 4 Principles, Recognizing and Declaring COI).
4. How do I declare external interests?
The Policy requires the disclosure of external interests at the time of your initial appointment, annually thereafter, and when a change in your circumstances gives rise to a conflict of interest (Article 5.2.2. Responsibilities of CIHR Members).
The declaration should be made in writing by using an approved declaration form (Declaration of External Interests Form), unless an alternative form of declaration is provided for by the COI Officer (Article 5.2.1.). Once the annual declaration form has been submitted, further updates to it can be made in the form of an e-mail message. Additional guidance is contained in the declaration form itself.
Please note that updates to the annual declaration and requests for advice to the Office of the COI Officer about a possible existence of a COI in an individual situation, are considered a declaration of external interest, and therefore, must be made by the person who makes a declaration himself or herself, and be supplemented by the available relevant information that is necessary for the Office to produce a well-informed and timely advice.
5. To whom should I submit my declaration?
Scientific Directors, members of the Governing Council and of its standing committees are invited to submit their declaration and related inquiries to the Office of the Conflict of Interest Officer at firstname.lastname@example.org.
Members of advisory bodies are invited to submit their declarations and related inquiries to the Chair of their respective bodies and to the Responsible CIHR Staff. Responsible CIHR Staff is the person(s) responsible for organizing/running the meetings along with the Chair.
Institute personnel should make their declarations to their respective Scientific Directors. According to the Policy, Scientific Directors are responsible for its implementation, and for preventing and managing COI situations at their respective institutes. (Section 2.2. Application).
6. How do I declare external interests during meetings?
- After having received the meeting agenda, alert the Chair of your external interests/engagements related to the subject of the meeting or to its individual items. Discuss the best way to avoid or manage a potential conflict.
- Next, disclose your relevant external interests and engagements to the members of the group at the beginning of the meeting or when the relevant item comes up for discussion.
- Abstain from participating in the discussion and/or decision-making on the issues in question as advised by the Chair.
- As a general rule, err on the side of "over-disclosure" when in doubt about the existence of a conflict or about the extent of the required disclosure.
For more information, please consult Section 5.3. of the Policy Responsibilities of the Chairs of Governing Council, Science Council and advisory bodies.
7. Whom do I consult regarding a potential COI situation?
CIHR promotes the idea of the disclosure of external interests as a continuous dialogue, and encourages open lines of communication between CIHR and its Members.
If you think that some of your external interests and engagements may prevent you from providing CIHR with an independent and impartial opinion, advice or other service, or you are not sure about the extent of the required disclosure, please discuss your circumstances, keeping in mind that:
- The Chair of the council, the committee or the advisory body of which you are a member is the best first point of contact.
- Scientific Directors are invited to seek the advice of the COI Officer regarding their personal COI situations, and if necessary, regarding those situations involving the personnel of their respective Institutes. Institute personnel should first consult their respective Scientific Directors.
- Members of Governing Council, as public office holders, are subject to the Conflict of Interest Act. They are therefore, encouraged to consult the Act and the Conflict of Interest and Ethics Commissioner regarding the standard of conduct established for them. They are also invited to consult the CIHR COI Officer regarding the standard of disclosure and the COI management practices established by the CIHR Policy (Section 2.2. Application).
- Chairs and Responsible CIHR Staff are invited to consult the COI Officer regarding policy interpretation and the unresolved issues with CIHR Members by sending requests to email@example.com.
8. Whom do I consult regarding a potential COI situation?
- If you need information, have a question regarding the interpretation of the Policy, or are in doubt about the need for or the extent of the required declaration, please direct your query to the Office of the COI Officer. Please make sure that you provide the Office with full details of the case, including full names of the organizations and projects involved , the type and the year of funding, etc. Please note that firstname.lastname@example.org is the recommended way of communicating and documenting confidential information.
- COI situations are very circumstance-specific, meaning that the response to each personal inquiry requires individual consideration, including research, consultation and approval. The Office will review the inquiry and will inform you about the timeline within which it will provide you with an advice or an answer. Requests for information and simple questions which do not require policy interpretation will normally be answered within 1or 2 working days.
- When conveying a highly sensitive or complex information or if you wish to have a discussion about a particular matter, you may request a face-to-face meeting or a teleconference with the COI Officer or her Office. Responses to all queries will be in writing.
II. What tools are in place at CIHR to prevent and manage conflicts of interest of Scientific Directors and members of Governing Council?
1. Can Scientific Directors compete for CIHR funding?
No. The CIHR Directive on Scientific Directors and CIHR Funding prevents SDs from competing for CIHR funding in any capacity (except as collaborators in some cases) during their term, thereby significantly reducing a risk of COI for them.
2. Do CIHR Scientific Directors or Governing Council Members take part in or influence peer-review or funding decisions?
No. CIHR relies on peer review committees to determine what applications to fund. The committees develop recommendations to the President who makes funding decisions. Members of the CIHR governing bodies (SDs and GC Members) are not permitted to participate in and therefore, cannot influence peer review process. For more information on how CIHR protects the fairness and impartiality of its peer review process please refer to the Conflict of Interest and Confidentiality Policy of the Federal Research Granting Organizations.
3. How does CIHR monitor actual, potential or perceived COIs of Scientific Directors and Governing Council Members?
- Proactive declaration of external interests is one of the essential steps towards identifying and managing any COI. SDs and GC members submit their declarations at the time of appointment, and annually thereafter to the Office of the COI Officer;
- There are standing COI declaration procedures during all committee meetings. For example, if the research of a SD’s or a GC member’s friend, associate or family member is implicated in discussions or decisions during Science Council or Governing Council meetings, a SD or a GC member will acknowledge their relationship and will abstain from related discussions and decision-making as advised by Councils’ Chairs.
- CIHR also has procedures and tools in place for the COI risk assessment, mitigation measures and compliance monitoring and reporting.
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