Conflicts of interest policy

BHF Funding Process: Conflicts of Interest Policy

Definition

• A conflict of interest exists when an individual’s personal and/or professional interests or loyalties may affect their objectivity.  
• A perceived conflict of interest exists when it could be reasonably considered by a third party that a conflict exists (irrespective of whether or not this is actually the case).  
  
  

General

• This policy relates to all research funding committees and panels, their chairs, other members and those co-opted.
• The purpose of this document is to enable mitigating processes when potential conflicts of interest arise, and to protect the charity and those who work for it from any perception, real or otherwise, that the external interests and affiliations of its committee members might interfere with their ability to work towards the charity’s objectives.
  
  

Declaration of interest

• Committee members must declare any disclosable external interest on their appointment to the committee, and annually thereafter. A register of interests will be kept up to date by the charity.
• Committee members should also adhere to the spirit of this document and declare any other interests which they feel may be a source of conflict, or which might be perceived to conflict, with the interests of the charity. This includes interests held by the committee members’ immediate family. 
  
  

Material conflicts 

BHF has two levels of restriction which are used to manage material conflicts of interest. The level of restriction depends on the nature of the conflict identified and the relevant committee, as follows:  

• A hard conflict exists when:

1. A committee member has a personal conflict of interest, e.g. if the principal applicant or a co applicant is a relative or if there are other circumstances that prevent them giving an impartial view of the application.
2. A committee member’s own application is being discussed.
3. A committee member is named as a co-applicant, collaborator or named staff member on the application.
4. A committee member is from the same institution as the principal applicant or a co-applicant.

• A soft conflict (specific to Chairs & Programme Grants Committee and Clinical Studies Committee) exists when:

1. A committee member is from the same institution, but a different department (or equivalent for institutions without a departmental structure) as the primary applicant or a co-applicant.
   
   

Managing conflicts of interests

• Where a committee member has a hard conflict, they must declare an interest and withdraw from any consideration of that application. That member will not receive documents pertaining to the application, learn the identity of its reviewers or receive reviewers’ reports. They must retire from the meeting when the application is discussed.
• Where a member has a soft conflict (specific to Chairs & Programme Grants Committee and Clinical Studies Committee), they must declare an interest. That member will receive documents pertaining to the application and can contribute to the discussion, but they will not usually be asked to formally review the application or chair the discussion.
• Committee members who could be seen as a direct competitor of the applicant (e.g. they are funded or applying for funding on a similar project to the proposal under discussion), or have collaborated closely, or published directly with the applicant within the past three years, should declare an interest and may be asked to retire from the meeting when the application is discussed.
• Where the chair of the committee is an applicant on a grant application, they must declare an interest and should retire from the meeting when that application is discussed. The vice-chair will chair the discussion.
• Where the chair and vice-chair are both conflicted on a grant application, either the Chief Scientific and Medical Officer or an Associate Medical Director will chair the discussion.
  
  

Resolution of conflicts of interest

• BHF recognises that the majority of conflicts or potential conflicts will relate to a particular issue and as such will not present any long term restrictions on an individual’s ability to sit on a committee.
• In a small number of cases, major conflicts of interest may arise which compromise an individual’s ability to continue in their position. Where this occurs, BHF will discuss the matter with the individual and chair of the committee.
• Members of research funding committees are expected to declare any potential conflicts of interest relating to individual funding decisions to BHF before the meeting where they will be discussed, or to the chair during the meeting as soon as the existence of a conflict becomes apparent.
• In cases where an individual is uncertain as to whether a conflict of interest exists or not, they should report this to BHF for a decision to be made, in consultation with the chair if appropriate.
• If an individual is concerned about a possible conflict of interest involving another member of a funding panel, then they should raise the matter with BHF before the meeting or to the chair during the meeting as soon as the possible conflict becomes apparent.
  
  

Written external peer reviewers 

If any material conflict of interest is identified, a reviewer will not be asked to provide a written review.

Staff members 

We expect anyone involved in the processing or assessment of an application and those observing the meeting, to identify any real or perceived conflict of interest they have related to the applicants and institutions named in the application. BHF will discuss the matter with the individual and decide whether they should withdraw from any consideration of that application.

22 July 2024