Procedure for Handling Conflicts of Interest
Approval Date: 2009-03-31
Effective Date: 2009-03-31
Responsible Unit: Office of the General Counsel
1. The University COI Committee or the Marine Institute COI Sub-Committee, as appropriate, receives the Conflict of Interest Disclosure Form from the Unit Head, considers the particulars of the situation including the recommendation from the Unit Head and decides whether a conflict of interest exists; whether it will be allowed to continue or must be discontinued; and, if it is to be allowed, what, if any, conditions should apply.
2. The applicable COI Committee or Sub-Committee shall determine the course of action that is in the best interests of the University. In making this determination, it will take into account the following factors:
2.1 the degree to which the proposed action would be detrimental to the integrity of the University;
2.2 any possible harm to the University or its Members, officers or others acting on its behalf if the conflict is allowed;
2.3 any possible harm to clients of University services, or others served by the University, if the conflict is allowed;
2.4 the extent to which the proposed action or activity may be managed through an appropriate protocol
2.5 whether reasonable alternative arrangements are possible which do not create a conflict of interest;
2.6 the educational, research, economic and other interests of the University;
2.7 the rights and interests of the University Member;
2.8 the impact on the Member's ability to satisfy his or her obligations to the University;
2.9 the consequences to the University if the conflict of interest is not allowed;
2.10 the consequences to the University if the conflict of interest is permitted to continue; and
2.11 the degree to which it may compromise an investigator's professional judgment in conducting or reporting research.
3. The COI Committee or Sub-Committee may request from the Member additional information that relates directly to and is necessary to assess and decide the real, perceived or potential conflict. The Committee may seek advice before making a decision relating to a real, perceived or potential conflict of interest.
5. In all cases, the Committee or Sub-Committee will issue a written decision to the Member who has declared the real, perceived or potential conflict of interest. The written decision will include the reasons for the decision. Where the decision is to manage the conflict, a process for doing so will be set out.
6. Once a decision has been made, Members are obliged to report any change of circumstances which could impact the initial decision in writing to the Unit Head using the Conflict of Interest Disclosure form. The original decision may be reversed or varied by the applicable COI Committee or Sub-Committee.