NIHR Conflicts of Interest Policy - Funding and Awards

Published: 11 September 2020

Version: 1.0 - May 2023

Purpose and scope

All reviewers, committee members and meeting participants involved in funding awards share responsibility for ensuring actual and potential conflicts of interest (COI) do not influence decision making. A potential conflict which is not declared or managed may result in or be perceived as having undue influence or bias. It may embarrass or put the credibility of the NIHR programme and its members at risk.

The integrity of reviewers, committee members and anyone involved in funding and award decision-making processes is of paramount importance. This means that personal and professional interests must never influence, or be perceived to influence, any outcomes. Everyone involved must make themselves aware of what NIHR considers potential or actual conflicts of interest and must act in accordance with this policy.

Principles

The underlying principles of this policy are those of the Nolan committee on standards in public life. All potential conflicts must be declared. No financial conflict is too small to be disregarded. Conflicts of interest information will be handled in accordance with NIHR’s Privacy Policy.

Judgements about potential conflicts of interest must take into account the need for decisions to be informed by expert reviewers and committee members. The risk of bias due to conflict of interest must be balanced against poor decisions arising from lack of access to appropriate knowledge and skills.

NIHR considers that conflicts of interest exist where committee members or reviewers:

are directly involved in the work that applicants propose to carry out
have personal relationships with applicants, defined as spouses or partners (current or past), children, siblings, parents, other close family members or close personal friends
work in the same department (immediate business area). For chairs this extends to the same institution as applicants. When an individual believes a conflict may exist beyond the department (or for chairs, institution) this should be declared
work closely with applicants, for example as collaborators, co-authors or PhD supervisors, or have done so in the last three years. There may be cases where an individual believes a conflict extends beyond the three year period and if so, this should be declared. Being a co-author may not always preclude someone from carrying out an external review, for example in the case of publications with very high numbers of co-authors when the individual has not worked closely with the applicant
may benefit financially from the work, for example if involved with a company acting as a project partner

This list is not exhaustive.

Conflicts of interests - funding competitions

Managing external reviewers’ potential conflicts of interest

It is the responsibility of each reviewer to declare conflicts of interests to NIHR staff as soon as they emerge or become apparent.

NIHR staff undertake COI checks based on reviewers’ institutional affiliations. If no conflicts are identified, requests for review are sent to reviewers.

If a new COI as defined by NIHR is declared once a review assignment has been made, the request will be withdrawn. The application will then be transferred to another reviewer. Any reviews submitted by a reviewer who is subsequently identified as conflicted are not accepted or used.

Detecting and declaring committee members’ potential conflicts of interest

Committee members are requested to declare their conflicts of interest ahead of review allocation, shortlisting, funding committee meeting agenda scheduling and interview scheduling. When committee members are uncertain about potential conflicts of interest, they should discuss with NIHRCC staff, who may refer queries to the committee chair. The chair will adjudicate on such potential conflicts, making a final decision according to the NIHR COI definition.

Any new conflicts of interest must be declared to NIHRCC staff as soon as they become apparent.

In the case of committee members who declare new conflicts of interest when assigned shortlisting reviews, a new member will be allocated to review. Any submitted reviews by conflicted members will not be accepted or used.

Handling COIs at meetings

A link to this policy is provided in the committee Terms of Reference. At each meeting, NIHR staff ensure that members are reminded of this COI policy through the chair’s brief. NIHR staff indicate all identified and potential COIs on the meeting schedule. Committee members must declare any previously undisclosed COIs at the beginning of the meeting.

Members do not have access to documentation relating to applications with which they are conflicted. Such documentation includes applications, peer and public reviews and committee member reviews. Members with conflicts of interest must not be present for discussion of and must not vote on conflicted items. Declared conflicts, and the names of those leaving the room or virtual room due to these conflicts, are recorded in the meeting minutes.

When a batch of applications are submitted against a tightly defined call for funding and only one application can be funded, conflicted committee members will remain out of the room or virtual room for applications that are in direct competition with the conflicted application in question.

Higher thresholds:
1) Infrastructure committee members are considered conflicted if applications are received from the same institution(s) where they are employed. This is because funding is awarded to the institution as a whole, rather than for individual research projects.

2) Chairs have a higher threshold for conflicts of interest than other committee members. They are considered to have a conflict if applicants are from the same institution, even if they are in a different department. Chairing items when the chair is conflicted are covered by committee Terms of Reference.

Exception to policy:
For specialist or niche areas, it may not be possible to both strictly enforce this policy and provide appropriate knowledge and expertise to inform committee discussions. In these exceptional cases, the chair must agree that it is necessary to deviate from this policy. A record with justification will then be logged in the committee meeting documentation, including the minutes.

Other meetings and forums

Other meetings and forums include, for example, monitoring reports, site visits, and email exchanges. Conflicted members should follow the spirit of this policy to judge whether they should be party to or contribute to discussions, or to be involved in any capacity.

Dealing with concerns about handling potential conflicts of interest

Any concerns regarding potential conflicts of interest should be sent to the specific programme point of contact or enquiries@nihr.ac.uk.

Responsibilities

NIHR staff

Directors, assistant directors and their teams must ensure compliance as laid out in this policy.

Non-NIHR staff

Chairs must comply with their duties according to this policy.

All reviewers and committee members must read this policy and are required to abide by it and all other supporting guidance relevant to their role. Reviewers and committee members are reminded that declarations or lack of declarations of interest are governed by the Fraud Act 2006. Committee members are made aware of the Fraud Act 2006 through the relevant Terms of Reference.