Resolution/mitigation – SGCs

Where there is an internal COI related to a SGC decision, the following steps should be taken:

  • SGC officials should recuse themselves or be required to abstain from discussions and decisions where their personal interests might influence or compromise their views and decisions.

  • SGC officials should, as a condition of employment, divest from or liquidate any private interests that might influence or compromise their roles and decisions.

  • SGC employees and officials with private/outside interests that may conflict with those of the SGC decisions, should be restricted from access to information that might advantage those private/outside interests.

  • SGC employees and officials with private/outside interests that may conflict with those of the SGC decisions, should be restricted from access to information that might advantage those private/outside interests..

If the conflict of interest cannot be eliminated or the individual refuses to divest from the conflicting private circumstances or interests, SGC officials with identified conflicts of interest can be sequestered, be asked to resign, or be dismissed from the SGC position.

Bribery and fraud committed by any SGC official are regarded as the basest forms of conflict of interest, and should be dealt with within the framework of criminal law.

Where there is an external COI related to an SGC decision, the SGC needs to have a policy in place to protect the integrity of its decision from outside influence.

For example, if approached by an external party who offers the SGC funding to complete its mandate (e.g. to enable the SGC to commission important health research), then the SGC should first identify whether a COI exists (see Module 3) and, if the risk benefit assessment permits management of the COI, implement other mitigation measures. These could include:

  1. placing conditions to the funding that ensure researcher independence.
  2. precluding a researcher receiving funding if they have a conflicted relationship with the product producer/company.
  3. Limiting any advertising or marketing advantage to be gained by the funder to what might be considered reasonable acknowledgement.

If the COI cannot be mitigated, the SGC should decline the funding. 

The Moderate Alcohol and Cardiovascular Health (MACH) trial is a case of a COI that involved a SGC where the COI was primarily external but there was also some internal COI.