Conflicts of Interest Policy and Procedures
Public trust in the integrity and independence of Sepsis Innovation Collaborative (SIC)’s review and decision-making processes as well as SIC’s adherence to high standards for the conduct of its activities is essential. It is also acknowledged and desired that volunteers and employees and others working on behalf of SIC (SIC Representatives) have myriad relationships, interests, and memberships that support and benefit the SIC mission. However, there are times when these multiple relationships may give rise to or give the appearance of an actual or potential conflict of interest. To protect both SIC and the SIC Representative, this Policy requires disclosure of relationships by SIC Representatives and resolution of any conflicts by SIC to ensure that actions taken are in SIC’s best interests. This protects SIC’s and the SIC Representatives’ decision-making from the appearance of bias or improper influence by individual personal or business interests in SIC.
All volunteer members participating in SIC activities and its professional staff should act in SIC’s best interests. Decisions always should be based solely on the best interest of the SIC, its membership, and the public. Decisions should not be influenced by personal financial interest or by other extraneous considerations. A good faith effort will be made to disclose any potential conflicts of interest. A potential conflict of interest exists if a person has a financial or other beneficial interest that may bias their decisions or actions related to SIC activities. However, in the interest of full disclosure, it is recommended that any relationship with a pharmaceutical, biotechnology, medical device, life science, or health-related company or venture be disclosed.
Representatives include, but are not limited to:
- Volunteer members of any and all SIC committees, working groups, task forces, and other entities [e.g., the Infection Management/Sepsis Collaborative Community (IMSCC)];
- Key Sepsis Alliance staff;
- Certain contracted parties or agents; and
- Other designated individuals in decision-making roles.
SIC Representatives are to make a good faith effort to fully disclose financial and non-financial relationships, including their employment, ownership interests, memberships, arrangements, investments and holdings, as required on the SIC Annual Conflicts of Interest Disclosure and Attestation form.
- Reporting is to occur before appointment or election and annually thereafter.
- An SIC Representative is expected to update their Disclosure Questionnaire also whenever any material change occurs in his or her relationships.
- In the course of SIC meetings or activities, the SIC Representative is to disclose any direct or indirect interests in a transaction or decision that potentially could be a conflict of interest.
Reporting these personal and other business relationships generally does not prevent an individual from working with or volunteering for SIC. SIC will evaluate non-financial and financial relationships for actual or perceived conflicts based on the nature of the SIC Representative’s position(s) and scope of decision-making authority, the substantiality of the relationships, the pervasiveness of the conflict, and whether additional measures are needed to protect the integrity and reputation of the SIC Representative and SIC.
Conflicts may be resolved by having the SIC Representative refrain from deliberating and/or voting on the particular transaction or matter in which he or she has an interest; and otherwise refrain from exerting any influence on SIC to affect a decision. However, other measures may be required by SIC, depending on the nature of and the ability to reasonably manage the conflict. Resolution will be based on the facts and circumstances of each individual situation, but may in some cases require action up to and including the withdrawal of the individual from the conflicting relationship or from the SIC position.
Requirements for Certain Positions
Because of the diversity of SIC’s activities, different volunteer and staff positions in SIC require specific and distinct procedures for addressing conflicts of interest. All procedures must be consistent with applicable law and this Policy.
Each SIC Representative shall annually complete and sign the SIC Annual Conflicts of Interest Disclosure and Attestation form which affirms that such person has:
- Received a copy of this Conflict of Interest Policy and Procedures;
- Read and understands the policy and procedures;
- Agreed to comply with the policy and procedures; and
- Completed a Disclosure and Attestation Statement. Such statements will be kept on file by Sepsis Alliance staff.