Declaration of Interests
In order to enable Inserm to identify conflicts of interest with the potential to undermine the authority of its expertise and its decisions, each individual participating in the missions of the Institute is required to disclose his or her interests. A procedure and a digital platform have been created with this in mind.
French law defines that any situation of interference between a public interest and public or private interests, of a nature to influence or appear to influence the independent, impartial and objective conduct of duties, constitutes a conflict of interest. The concept of interest covers the professional and financial links that unite a natural person with a legal person or with another natural person whose activity falls within the remit of Inserm. It also concerns institutional, familial, intellectual and moral links.
The purpose of the declarations of interests is to identify these links and evaluate them on the basis of objective and robust criteria.
In accordance with the commitments set out in the Inserm expertise charter and incorporated in the French national ethical charter for researchers, Inserm has implemented a procedure for managing these interests and these conflicts of interest, which was approved on October 6, 2011 by its Management Board.
- A form and an analysis grid to facilitate this procedure are available on the Intranet for Inserm staff.
- A digital platform enables them to disclose any interests.
The types of interest proposed in the declaration formalize the most common situations and is not exhaustive. It is therefore the responsibility of the individuals concerned to examine and disclose any element past or present, foreseen or unforeseen in the declaration, which are liable to bias their judgement or generate the suspicion of conflicts of interest between their missions for the Institute and their external activities.
As a priority, this procedure is aimed at the members of the Inserm Management Board, Scientific Advisory Board, Specialized Scientific Committees, as well as the experts called upon to participate in the Collective Expert Reviews. Its purpose is encompass more broadly any committee or board set up by Inserm, from the moment that they are required to make decisions or formalize recommendations likely to influence the decisions made by Inserm Senior Management. It is the responsibility of the departments in charge of organizing these committees or boards to implement the ad hoc procedures in compliance with the principles adopted by the Management Board concerning the management of interests and conflicts of interest.
In addition, the activities of Inserm may be subject to foreign legislation, either due to the application of local law when the activities are conducted in the country concerned, or due to the extraterritorial application of certain legislation such as the US and UK anticorruption laws (US Foreign Corrupt Practices Act 1977, UK Bribery Act 2010) or the National Institute of Health Grants Policy Statement (NIH GPS).
National Institute of Health and Medical Research (Inserm) procedures regarding applications to and awards from NIH concerning Financial Conflict of Interest (FCOI) policy
On 1 August 2012, the NIH implemented a new set of policies relating to conflicts of interest applicable to organisations where they fund research. The policy and extensive guidance is accessible here and FAQ Section provides a guide through the requirements.
In accordance with the policy, Inserm’s own procedures for implementing the NIH’s requirements are available to the public to download here.
The policy applies to everyone (university researchers, honorary staff, students, consultants, external collaborators etc) who is responsible for design, conduct and reporting of research funded by the NIH itself, by NIH Institutes and by the Public Health Service of the US Department of Health and Human Services (of which the NIH is a part).
The NIH policy is supplementary to, and followed in conjunction with, the Inserm’s existing policies, procedures and guidelines on related matters, such as Conflicts of Interest and Good Practice in Academic Research, which are available from the Governance Zone.
