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Conflict of Interest in Research Policy

Royal Roads University Policy

Policy Number: 
C1050
First implemented: 
November 5, 2009
Approved By: 
Board of Governors
Office of Oversight: 
Vice-President Academic

Preamble and Purpose

Royal Roads University (RRU) is committed to academic freedom and excellence in research. It encourages its Members to pursue research and related professional activities that are compatible with the University’s mission, vision, and mandate and in accordance with the highest ethical standard.

The purpose of this Policy is to establish principles, practices and procedures to ensure the integrity of research and scholarship carried out under the auspices of RRU as it relates specifically to matters of conflict of interest in research. The Policy aims to provide an environment for research that ensures integrity and a high ethical standard, thereby enabling public and professional trust and confidence in the manner in which research and related professional activities are conducted.

Given the complexity of the University’s and RRU Members’ relationships with external individuals, organizations, and communities, the University recognizes that conflicts of interest in research will inevitably occur. A conflict of interest arises from a particular situation. It does not arise from or reflect upon the character of the individuals involved. The University seeks to identify these conflicts of interest in a timely fashion and to address them as appropriate through a fair, transparent and efficient mechanism. At the core of this Policy is the duty of each RRU Member to assess his or her own research-related activities and to report any real, perceived or potential conflict of interest in research as prescribed in this Policy and accompanying Procedures.

More specifically, the purposes of this Policy are:

To require that actual, perceived or potential conflicts of interest in research are disclosed and appropriately considered; and

To provide a framework for addressing conflicts of interest in research that is timely, fair, transparent, consistent and efficient.

Definition of Conflict of Interest

2.1. “Conflict of interest” may arise when activities or situations place the University or an RRU Member in a real, perceived or potential conflict between their duties or responsibilities related to research and their personal, institutional or other interests. Conflict of interest may occur when the University’s or RRU Member’s judgments and actions in relation to research are, or could be, affected by personal, institutional or other interests, including, but not limited to, business, commercial or financial interests, whether of the RRU Member or Closely Associated Persons, or their former, current or prospective professional associations, or of the University itself.

Examples of conflict of interest in research include but are not limited to:

Evaluating the research or writing, or any other activity, of a colleague who is also a direct competitor of the RRU Member.

Contributing to a decision on the hiring, evaluation, advancement, or scholarly work of an individual if the RRU Member has a previous ongoing connection (positive or negative) with that individual (i.e. a Closely Associated Person, e.g., spouse, relative, friend; or student supervisor/advisor).

Entering into an agreement with a sponsor(s) wherein advantages are promised, formally or informally, to researchers for findings that are favourable to the sponsor(s). This may involve, among other things, the payment of money, royalties, or grants or the transfer of shares or options in the sponsoring company.

Supervising research personnel, including students, technicians and/or staff, employed by a related business, i.e. in which the RRU Member has a financial or other interest.

Supervising research work of a Closely Associated Person, i.e. someone to whom the RRU Member is related or with whom he or she has a close personal relationship.

Using University or sponsor resources for private business purposes.

Using information acquired in the course of research activities, which is not in the public domain, to advance a RRU Member’s personal or financial interests or those of a related business.

Entering into a licensing agreement for the development of intellectual property, generated as the result of University research with a company in which the RRU Member has a financial or other interest.

Other Definitions

3.1. “Administrative Head” of:

the President is the Board of Governors;

a Vice-President is the President;

an Associate Vice President is a Vice President or the President;

a Dean is the Vice-President Academic & Provost;

a Chair, Head or academic Director is the Dean of that Faculty;

the Director or equivalent of an administrative or other non-teaching unit is the Vice-President or Associate Vice President responsible for that unit;

any other RRU Member who is employed at the University:

  • with a faculty position is the Dean;
  • in other than a faculty position is the Dean of the Faculty, or the Administrative Director or equivalent of the unit, in which the RRU Member works;

an RRU Member who is a student is that student’s Program Head;

any other person who is not an employee of Royal Roads University or a student is the Vice-President Academic & Provost or the appropriate Dean or Administrative Director as determined by the Vice-President Academic & Provost;

3.1.1 Decisions of the RRU Research Ethics Board may be referred to the REB of an external institution designated to act as RRU’s Research Ethics Board’s appeal board.

3.2.  “Closely Associated Person” refers to a person related to the RRU Member by blood, adoption, marriage or common-law marriage, or with whom a RRU Member has a close personal relationship; it may also include an individual with whom a RRU Member has had such a relationship.

3.3.  “Financial Interest” refers to the receipt or expectation of anything of monetary value, including pay or salary or other payments for services (e.g., consulting fees, bonuses, speaker’s fees, advisory board remuneration, finders or recruitment fees, or honoraria), equity interests (stocks, stock options or the like), security or other ownership interests, and intellectual property rights (e.g., patents, copyrights, royalties or carried interests or options related to such rights).

3.4.  “Conflict of commitment” occurs where the external or personal activities and undertakings of a RRU Member are, or might reasonably be perceived to be, so substantial as to interfere with the RRU Member’s primary commitment to the University. For the purposes of this policy, a conflict of commitment is a form of conflict of interest.

3.5.  “Personal Interest” means the personal, private, or financial interest of a RRU Member or closely associated person or related business.

3.6. “Related Business” means a business or society in which the RRU Member or any Closely

Associated Person:

a)  has a financial interest;

b)  acts as a trustee, director or officer;

c)  acts in a position as an employee, agent or otherwise which includes responsibility for a segment of the operation or management of a business; or

d) acts in a position as an employee, agent or otherwise which includes responsibilities for influencing or determining the scientific direction of the corporation.

3.7.  “Research” is defined as systematic inquiry for the purpose of gaining new knowledge or new understanding or new application. For the purposes of this policy, Research includes all activities and products related to research and may be generated as part of a research grant, a research contract, an institutional based consulting contract, an institutional service contract relating to academic matters or any other institutionally based contract other than direct instructional contracts, as well as student research as part of academic programs (e.g. theses, organizational consulting projects, major projects, class assignments, papers, reports, internships, etc.).

3.8.  “RRU Faculty” refers to faculty as defined by the RRU Board of Governors to conduct teaching, research, and administration.

3.9.  “RRU Member(s)” includes the following: RRU employees, including full-time, part-time, and casual employees as well as contractors, RRU Faculty (as defined in Section 3.8), RRU graduate and undergraduate students, other non-degree students, RRU post-doctoral fellows, research assistants, visiting workers and those otherwise affiliated with the university (e.g., adjunct professors, etc.).

3.10.  “Policy” means this RRU Conflict of Interest in Research Policy, including any and all supporting documentation, forms and related RRU policies, and the relevant sections of other RRU agreements and Policies, as applicable.

3.11.  “University” means Royal Roads University.

Applicability

4.1. This Policy applies to all RRU Members, as defined in Section 3.9 above.

4.2.  This Policy applies to all research activities, whether the research is sponsored by the University, by an external funder, or by an RRU Member personally.

4.3.  This Policy applies to all research activities being conducted under the auspices of the University. Unless a contrary intention is clear, such research includes:

a)  research being conducted by, or under the direction of, an RRU Member;

b)  research being conducted or directed by an RRU Member under the direction or sponsorship of entities wholly or partly owned or controlled by RRU;

c)  research conducted or directed by entities wholly or partly owned or controlled by RRU within facilities wholly or partly owned or controlled by RRU.

The Conflict of Interest in Research Policy

A RRU Member shall not participate in an activity or decision that involves an actual, potential or perceived conflict of interest in research unless such activity or decision has been approved in advance by the Administrative Head and, if such approval has been given, any terms or conditions made by the Administrative Head regarding such activity or decision are fulfilled.

5.1.  Where an actual, potential or perceived conflict of interest in research arises, it must be immediately disclosed by the RRU Member(s) involved. It may be necessary that the activity be placed on hold pending assessment.

5.2.  The conflict of interest will be assessed in a timely, fair and open manner per the Conflict of Interest in Research Procedures that accompany this Policy.

5.3.  A conflict of interest in research is to be allowed only when it can be managed in a way that protects and serves the interests, integrity and reputation of the University, as well as its legal and contractual obligations, and will stand the test of reasonable and independent scrutiny.

5.4.  Non-compliance with this Policy and its associated procedures constitutes misconduct and may be pursued under the University’s Policy and Procedures on Academic Integrity and Misconduct in Research and Scholarship.

5.5.  The University reserves the right to recover any profit or financial benefit achieved by a RRU Member as a result of non-compliance.

Procedures Established Under this Policy

See Conflict of Interest in Research Procedures for the procedures to disclose, assess and manage Conflicts of Interest.

Implementation

The Vice-President Academic and Provost has executive responsibility for implementing and communicating this Policy.

Amendments

Major amendments to the Conflict of Interest Policy in Research must be approved by the RRU Board of Governors.

Related Policies

This Policy should be read in conjunction with the following University Policies:

  1. RRU Policy and Procedures on Academic Integrity and Misconduct in Research and Scholarship
  2. RRU Research Ethics Policy
  3. RRU Conflict of Interest Policy

Dates

05.11.09 - Board Approval
05.11.09 - Effective
05.11.15 - Review due (approval date + five years)

Source

Recommended by Academic Council August 14, 2009; Recommended with some amendments by Program and Research Council October 26, 2009; Approved by the Board November 5, 2009