A conflict of interest occurs when your personal interests and your professional obligations are different. To determine if you have a conflict of interest, ask yourself if an independent observer would question whether financial or personal gain influenced your duties or professional judgment, or if they influenced how you presented scientific evidence, publications, testimony or presentations.
A financial interest is when you have something of monetary value given to you by a for-profit individual or industry. This includes:
- Compensation (salary, bonuses, income, honoraria, etc.)
- Equity interests (stocks, stock options, convertible security, etc.)
- Revenue or royalties from Intellectual Property (IP) rights
An external interest is an outside relationship or activity, not related to PHSA, such as board membership, directorship, ownership, etc.
You can have financial or external interests that are not in conflict with your role or responsibilities at PHSA. However, you would have a conflict of interest if you (or a person related to you) has a financial or external interest with an individual/industry that:
- PHSA has a business relationship with,
- Contradicts the values or mission of PHSA's academic health sciences mandate,
- Relates to your area of research, or
- Is connected to your PHSA role (procurement, HR decisions, etc.).
You should disclose any financial or non-PHSA external interests that pose a real, perceived, or potential conflict of interest. You do not need to disclose financial or external interests that do not pose a conflict, nor equity interests that are held through publicly-traded mutual funds, pensions, nor other institutional investment funds over which you have no control.
If your COI declaration indicates a potential conflict, you must include in your form a plan for appropriately managing this conflict. Your plan should agree with the values and mission of PHSA, protect patient welfare, and make certain that your research outcomes are unbiased.
To manage a COI you can:
- Take no action, if the conflict is minimal or the benefits outweigh the negatives, and the conflict does not impact your reputation declaration alone is required;
- Modify the interests and/or study, if the conflict is significant but the risk can be adequately managed; or
- End the interests and/or study, if the conflict is substantial no matter how you modify it.
Ways to manage your COI could include:
- Restructuring the financial interest, such as reducing the value or postponing the payments
- Prohibiting the licensing of IP rights to an individual or industry that you have an interest in
- Modifying your role or responsibility
- Using an independent person to monitor the study
- Changing the research plan or your role in the research, such as eliminating interaction with human subjects or participation in data interpretation
- Eliminating the interest
- Notifying colleagues, others on the study, members of committees and boards, students, and trainees of the interest
- Providing notification of the interest in publications, presentations, abstracts, and press releases
- Withdrawing from discussions that involve the individual or industry that you have an interest in
- Taking a leave of absence from your position at PHSA