Royal Free Charity | Conflicts of interest policy

Conflicts of interest policy

General

  1. This policy relates to any research funding panels or sub-panels of the charity, their chairs and members. 
     
  2. 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 panel members might interfere with their ability to work in the best interests of the charity. 
     
  3. Panel members 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’ partner or children.

Discussion of applications

  1. 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. 
     
  2. Discussions of an application between members of a funding panel which occur outside a panel meeting should be declared to the chair of the panel. 
     
  3. If a panel member is approached by an applicant for technical advice on an application, they may provide advice, but must report this to the panel chair and secretariat. They may subsequently be asked by the chair to absent themselves from a discussion of the application concerned.

Managing conflicts of interest

Members of funding panels are expected to declare any potential conflicts of interest relating to individual funding decisions to the panel secretariat before the meeting wherein they will be discussed, or during the meeting as soon as the existence of a conflict becomes apparent. 

Where a conflict of interest is identified, the chair or member will not receive documents relating to the application, learn the identity of its reviewers or receive the reviewers’ reports. They must retire from the meeting when the application is assessed. Conflicts include: 

  1. Where a panel member is an applicant, co-applicant or collaborator on a grant application, they must declare this and withdraw from any consideration of that application. They must also retire from the final recommendation at the end of the meeting. Details of discussion of that application will be deleted from any papers the member receives. 
     
  2. Where the chair of the panel is an applicant, co-applicant or collaborator on a grant application, they must declare an interest and should not be involved for the whole meeting. A vice chair will chair the meeting to prevent any undue influence. 
     
  3. Panel members who could be seen as a direct competitor of the applicant or coapplicants (e.g. they are funded or applying for funding on a similar project to the application under discussion). 
     
  4. Panel members who have collaborated or published with an applicant or coapplicants within the past three years. If the publication is the work of a consortium or equivalent where many people are involved, this will not be regarded as a conflict. 
     
  5. Panel members who work in the same institution as the applicant or co-applicants, or have been in the previous twelve months. 
     
  6. Panel members who are from the same institution as a collaborator on an application are not necessarily regarded as conflicted. 
     
  7. Panel members who are a relative of the applicant, co-applicants or collaborators. 
     
  8. Panel members who are a business partner, or have a financial interest in the grant application, of the lead applicant, co-applicants or collaborators. 
     
  9. Panel members who are in a supervisory relationship (now or in the previous five years) with the lead applicant or co-applicants.

Resolution of conflicts of interest

  1. 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 sit on its panels. 
     
  2. In a small number of cases, major conflicts of interest may arise which compromise an individual’s ability to be a member of a funding panel. In these cases, the matter will be discussed by the chair of the panel together with the secretariat. In cases where agreement cannot be reached through this means, the case will be referred to the panel as a whole, whose decision should be taken as final. 
     
  3. In cases where an individual is uncertain as to whether a conflict of interest exists or not, they should report this to the panel 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. 
     
  4. If an individual is concerned about a possible conflict of interest involving another member of a funding panel, then they should raise the matter with the chair of the panel or secretariat.

Declaration of interest

  1. Any persons covered by this policy, as defined in paragraph 1.1, 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. 
     
  2. 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.

Updating the policy

The charity will endeavour to review this policy, if necessary, every two years.

Downloads

A printable version of this policy is available for your records: