Conflict of Interest Policy

Introduction

It is essential that the personal and institutional interests of those involved in reviewing applications do not influence the decision-making process. All those involved share responsibility for ensuring this. Accordingly, it is important that Panel members or observers (hereafter Panel member), peer reviewers, public reviewers and public members of Panels are aware of what constitutes a potential or actual conflict of interest (COI). The purpose of this document is to set out the Policy for identifying and handling COIs at any review Panel meeting irrespective of it being held face to face or remotely (i.e. teleconference, videoconference).

Underlying principles

● The underlying principles of this policy are those of the Nolan committee on standards in public life.

● Consistency across SBRI Healthcare and with similar research funding organisations is desirable but programmes must be able to flexibly interpret the policy and its definitions.

● A potential conflict which is not declared and managed may result in undue influence or bias, embarrass or put the credibility of the programme and its members at risk.

● It is also important that there are sufficient review Panel members who have the appropriate knowledge and skills to make an informed decision. Each decision to exclude someone from a review Panel must balance these competing risks of bias due to conflict of interest versus wrong decisions from lack of expertise.

Definition of conflicts of interests

The integrity of a Panel member and peer reviewer is of paramount importance. This means that any personal interests must never influence, or be seen to influence, the outcome. All potential conflicts should be declared and no de minimis level for financial conflicts should be used or assumed. This list is not exhaustive, so if a conflict of interest is considered it must be declared at the outset.

We consider that a conflict of interest exists where panel members or reviewers:

1. Are directly involved with an application.
2. Have a partner, close family member or friend as an applicant on the proposal being assessed OR on a competing proposal.
3. Work in the same department of the institution as the lead applicant, team members, sub-contractors, advisors or clinical/healthcare professional partners.
4. In the case of Chairs or Co-chairs, work in the same institution as the lead applicant, team members, sub-contractors, advisors or clinical/healthcare professional partners.
5. Work closely or have done so within the last 3 years with the lead applicant, team members, sub-contractors, advisors or clinical/healthcare professional partners, for example as a co-author, collaborator or PhD supervisor.
   a. Please note that conflicts may extend beyond the 3-year period and should be declared in these cases.
   b. Co-authoring publications with an applicant(s) with a very high number of co-authors may not preclude an individual from reviewing. In these cases, a conflict should still be declared for consideration.
6. May benefit financially from the work (for example, if involved with a company acting as a project partner) or have a financial or commercial interest in the work (for example, in receipt of pensions, consultancies, directorships, honoraria, significant shareholdings, financial interests or voting rights in companies).
7. Have a Partner or close family member who may have a financial or commercial interest (for example, in receipt of pensions, consultancies, directorships, honoraria, significant shareholdings, financial interests or voting rights in companies).

This list is not exhaustive.

Detecting/declaring potential conflicts of interests

● In the first instance SBRI Healthcare Programme Management Office (PMO) will assess for COIs during review allocation and shortlisting meeting/interview scheduling.

● Review Panel members or peer reviewers will declare any additional COIs to SBRI Healthcare PMO following review allocation and at shortlisting meetings/interviews.

● The relevant Panel Chair should offer advice and adjudicate on the nature of the potential conflict and rule on if it requires acting on with the support of SBRI Healthcare PMO.

● It is the responsibility of each review Panel member to declare interests to SBRI Healthcare PMO and the Chair as they emerge or as members become aware of them.

● Panel members will be asked to complete a declaration of interests form when they join a Panel and at least annually thereafter. It is their responsibility to ensure that any relevant updates are provided as and when they occur.

Handling COIs at shortlisting review or external peer review

● Conflicted review Panel reviewers or peer reviewers will not be assigned the application in question.

● If a new COI is declared once a review assignment has been made the application will be transferred to another review Panel member or peer reviewer. External peer reviewers to be thanked for their involvement.

Handling COIs at shortlisting meetings/interviews

● All COIs will have been indicated on the meeting schedule by SBRI Healthcare PMO.

● Review Panel members will declare any undisclosed COIs as soon as encountered.

● Conflicted review Panel members will leave the room during discussion of the application in question and be invited back by a member of PMO once the discussion is complete. If the Chair has a potential conflict of interest the deputy Chair should chair the item and rule if the Chair may remain and contribute to the discussion.

● In the event of both Chair and Deputy Chair having a potential conflict of interest requiring both to leave the room, the particular agenda item will be chaired by another member of the Panel as identified by the Programme Director/Panel Chair or senior member of the PMO.

Other meetings/forums

These include, for example, monitoring reports, site visits, email exchanges. Conflicted members should follow the spirit of the above policy with the same context in regards to whether they should be party or contribute to discussions, or be involved.

Dealing with concerns regarding potential conflicts of interest

Any concerns regarding potential conflicts of interest should be sent to sbri@lgcgroup.com. These will then be directed to the respective centre, who have a confidential process for dealing with potential conflicts of interest and will oversee the independent review of allegations received. Further information on whistleblowing is available.

Overall Responsibility

● Directors, Assistant Directors, Panel Chairs and their teams must ensure the policy is complied with.

● Chairs should regularly communicate the policy and adjudicate on specific instances of potential conflicts with their review Panel or board members.

● SBRI Healthcare PMO attendees will ensure the policy is adhered to at each meeting.

● All Panel members must have sight of this policy and agree to abide by it and all other supporting guidance relevant to their role before undertaking any review of applications. This agreement must be made in writing and be recorded by SBRI Healthcare PMO. Guidance to Panel members should include reference to the Fraud Act 2006 and the potential consequences in relation to this of failing to comply with this policy.