Subject: Policy on Conflicts of Interest in Research
Approved by: Provost and Vice-President, Academic & Research
Approval date: April 28, 2009
Effective date: April 28, 2009
Administered by: Provost and Vice-President, Academic & Research
1 — INTRODUCTION
Mount Allison is committed to the highest standards of integrity in research and scholarship and recognizes that conflicts of interest must be identified and managed in a clear, transparent and accountable fashion to protect the credibility of the research enterprise and to maintain public confidence and trust.
Conflicts of interest may arise when there is a real, perceived or potential conflict between
a) the duties or responsibilities of University personnel, members of the Research Ethics Board, or the University itself related to research activities, and
b) their personal, institutional or other interests, including, but not limited to, the business, commercial or financial interests of themselves, their family members, friends, former, current or prospective professional associations, or the University itself.
2 — APPLICATION OF THIS POLICY
This Policy applies to the University itself and to University personnel who for the purposes of this Policy are defined as faculty, students, postdoctoral fellows and other persons, including, but not limited to, research associates, technical staff, adjunct professors, visiting professors, administrators and officials representing the University, who are involved directly or indirectly in research.
3 — ACTIONS THE UNIVERSITY WILL TAKE
The University will
a) administer this Policy consistently and effectively;
b) advise the relevant Tri-Council or other appropriate external funder, on request, of how the Policy is being administered;
c) ensure that all individuals to whom this Policy applies are appropriately informed of their obligations and responsibilities under the Policy;
d) make every reasonable effort to ensure that conflict of interest situations are disclosed and
e) appropriately managed prior to any commitment or expenditure of research funds; and disclose in writing to the relevant Tri-Council or other appropriate external funder any conflicts of interest that may affect a decision about a specific application or request for a grant or award.
4 — CONFLICTS OF INTEREST BY UNIVERSITY PERSONNEL
University personnel must disclose in writing to the Provost and Vice-President, Academic and Research, any actual, perceived or potential conflicts of interest in respect of any of their research.
This disclosure must include the details on the research, budgets, commercial interests, consultative relationships and other relevant information.
The Provost and Vice-President, Academic and Research, in consultation with the Senate Research and Creative Activities Committee and/or the Research Ethics Board, as appropriate, will assess the likelihood that the researcher’s judgment may be influenced, or appear to be influenced, by any actual, perceived or potential conflicts of interest, and assess the seriousness of any harm that is likely to result from such influence or from the appearance of such influence. (The “Assessment.”)
In particular the Assessment will consider whether an outside observer would
- a) question the ability of the researcher to make a proper decision despite possible considerations of these interests, or
- b) believe that the trust relationship between the relevant parties could reasonably be maintained if they had accurate and complete information on these interests.
In some cases, the Assessment might conclude that the identified conflict of interest does not warrant specific actions.
In other cases, the Assessment might require the researcher to disclose this conflict to the prospective research subjects during the process of free and informed consent.
The Assessment might also require disclosure to the sponsors of the research, relevant professional bodies or the public at large.
If the conflict is so pervasive that disclosure is not sufficient, the Assessment might require that the researcher
- a) abandon one or more of the interests in conflict,
- b) withdraw from the research, and/or
- c) permit others to make research-related decisions.
5 — CONFLICTS OF INTEREST BY RESEARCH ETHICS BOARD MEMBERS
To maintain the independence and integrity of ethics review, members of the Research Ethics Board must avoid conflicts of interest.
Members must disclose actual, perceived or potential conflicts of interest to the Board in respect of research that is being reviewed by the Board. The proposer of a research project must also be given the opportunity to present evidence of a conflict of evidence with a Research Ethics Board member. In such cases, the Board will decide whether the member must withdraw from the Board when the project is under consideration.
In any case where the member’s own research projects are under review, the member must withdraw from the Board when such projects are under consideration.
To ensure that there are no real, perceived or potential conflicts of interest in the participation of University Personnel in external research ethics boards, University Personnel must have the permission of the Provost and Vice-President, Academic and Research before accepting any honoraria or other consideration for participation in such boards.
6 — INSTITUTIONAL CONFLICTS OF INTEREST
Mount Allison respects the autonomy of the Research Ethics Board and recognizes that the Board must
- a) maintain an arm’s-length relationship with the University,
- b) avoid and manage real, perceived or potential conflicts of interest, and
- c) resolve all ethical questions before a project can be approved.