Draft conflicts-of-interest policy
Consultation on the policy governing the declaration and management of interests across the Institute, covering assessment committee members, external reviewers, contributors and respondents to consultations. The draft proceeds from the position that a…
§1Consultation and window
§1.1Window
- Opened
- 26 January 2023
- Closed
- 23 March 2023
- Duration
- 56 days
- Status
- Closed — the disposition is published
- Document under consultation
- Governance document
- Submissions received
- 12
§1.2Consultation questions
The secretariat put the following questions. A submission was not required to address them and several did not; the questions record what the Institute was uncertain about rather than restricting what a respondent could raise.
- Should an industry submission be identified as such on its face, or is publication of the declared interest sufficient?
- Is the materiality threshold for a shareholding set at a level that captures the holdings a reader would consider relevant?
- Should recusal be automatic on any declared financial interest, or determined case by case against the specific document?
§1.3How a submission is handled
- Every submission is signed. The Institute publishes no anonymous submission.
- Every submission carries a declared interest. A declaration of no interest is itself a declaration and is recorded as one. A declaration is not a disqualification and the Institute has never given a submission less weight on that ground.
- A submission from an employee of a marketing-authorisation holder is identified as an industry submission on its face, following a unanimous consultation on the conflicts policy.
- Every submission receives a secretariat response and a disposition. Submissions that are not accepted remain published in full; the Institute does not remove a submission because it disagrees with it.
- There is no voting, no reputation score, no reply thread and no editing after receipt.
§1.4Outcome
The policy was ratified with amendments. Every respondent who addressed the first question supported identifying an industry submission on its face, and that requirement now applies across the consultation record. Recusal remains determined against the specific document rather than applied automatically.
The disposition table, listing each submission with its disposition and the resulting amendment, is at §3.