Conflict of Interest Policy

Preamble

The Pacific Institute for the Mathematical Sciences (PIMS) is a consortium of universities in Western Canada and Washington State that facilitates and promotes the mathematical sciences. PIMS is committed to best governance practices and to protecting the integrity of its research, educational, and adjudication activities. Research integrity and academic freedom are cornerstones of all PIMS activities, and it is incumbent on the Institute to ensure these principles are protected at all times.

At PIMS, conflict of interest is a broad term that includes real, potential, and perceived conflicts. A conflict of interest is a situation, not an accusation. Being in a conflict of interest is not the same as wrongdoing, and identifying that an individual is in a conflict of interest is not an allegation of bias or lack of integrity. The purpose of this Policy is to ensure that such situations are disclosed early, reviewed consistently, and managed transparently so that no doubt is left about the objectivity of a PIMS decision-making process or the integrity of a PIMS activity.

This Conflict of Interest Policy is a companion to the PIMS Operational Procedures, the document that governs the internal operation of PIMS. Section 1 defines various types of conflicts of interest. Sections 2-5 of this document are taken from the PIMS Operational Procedures, which was adopted by the PIMS Board and ratified by all member universities.

1. Definitions and Scope

1.1 PIMS Participant

For the purposes of this Policy, a PIMS participant means any individual involved in a PIMS activity, program, governance process, review process, committee, panel, adjudication, or administrative function. This includes, as applicable, Board members, members of the PIMS Directorate, Site Directors, staff, committee and panel members, reviewers, applicants, nominees, organizers, invited participants, partners, trainees, and other individuals participating in or influencing a PIMS activity.

1.2 Conflict of Interest

A conflict of interest (COI) is a situation in which an individual has competing interests, obligations, or loyalties that could affect, or could reasonably be seen to affect, the impartiality of a decision the individual makes or influences during a PIMS activity or PIMS governance. A conflict of interest arises whenever an individual is in a position to benefit personally, directly or indirectly, and whether financially or otherwise, from a decision they make or influence.

1.3 Potential Conflict of Interest

A potential conflict of interest is one that does not yet exist but could reasonably develop in the future. For example, where a PIMS participant is contemplating a collaboration or employment with an organization, or contemplating an ownership or financial interest, that would create a conflict were it to proceed. A potential conflict is disclosed and managed in much the same way as an actual conflict, with the management response depending on the likelihood and significance of the conflict materializing.

1.4 Perceived Conflict of Interest

A perceived conflict of interest exists where a reasonable, informed observer could apprehend that a conflict exists and that the individual may not be able to act impartially, whether or not an actual conflict exists in fact. Perceived conflicts matter because, if not handled appropriately, they can create a risk of reputational harm to the Institute or its personnel. A perceived conflict is handled in substantially the same manner as an actual conflict, although how it is managed will depend on whether an actual conflict is also present.

1.5 Personal Benefit and Related Persons

A personal benefit includes any financial gain, professional advantage, or other advantage accruing to the individual or to a relative or close business or financial associate of the individual. A conflict of interest may arise through such a related person where, for example, the relative or associate holds an ownership interest in, or a position of influence over, an organization involved in a PIMS activity.

1.6 When a Conflict of Interest Exists

For the purposes of this Policy, a conflict of interest exists where any of the following applies:

1. a PIMS participant has a direct or perceived influence on the decision-making process for a PIMS activity from which the participant would benefit personally;
2. a PIMS participant has a financial or decision-making interest, whether held directly or through a relative or business associate, in an organization involved in a PIMS activity that could result in personal benefit; or
3. a Board member, member of the PIMS Directorate, member of an advisory panel or committee, Site Director, or staff member has influence over a decision that could result in a personal benefit to them.

1.7 Disclosure and Management

Being in a conflict of interest does not necessarily bar an individual from participating in a PIMS activity or from PIMS governance. Rather, each situation is reviewed to determine how the conflict can be managed, and an appropriate management pathway is developed for that situation. Practices ensuring timely disclosure, transparency, and consistency are used throughout.

Individuals are expected to disclose real, potential, or perceived conflicts of interest as soon as reasonably possible. Unless a more specific procedure applies, disclosure should be made to the relevant committee chair, program lead, Site Director, Director, Board Chair, or other appropriate PIMS decision-maker. The recipient of the disclosure will determine the appropriate management pathway or refer the matter to the appropriate PIMS body. Possible management measures include disclosure to the relevant body, reassignment of duties, restriction of access to confidential material, non-participation in discussion, non-participation in scoring or voting, recusal from the decision, or another measure appropriate to the circumstances. The goal is not to exclude participation unnecessarily, but to preserve fairness, confidentiality, transparency, and confidence in PIMS decision-making.

2. Practices of the Board

In case of any real or perceived conflict between an individual’s duties and responsibilities as a Board Member, and an individual's private, business, or public interests, the Board member will discuss the situation with the Chair of the Board to determine the best course of action for managing the conflict. A conflict may arise if the Board Member would derive a personal or financial benefit from matters arising in Board business, especially pertaining to PIMS finances. Board Members will recuse themselves if they have a personal or professional conflict of interest with respect to a matter before the Board.

3. Scientific Review Panel (SRP)

Information discussed in the SRP meeting is considered Confidential Information. The SRP is bound by Confidentiality. The Terms of Reference for the SRP, distributed to the SRP members,  contain specific instructions to the panel for maintaining Confidentiality and for managing Conflicts of Interest when they arise. The SRP follows well-established practices for peer-review of grant applications which include: up front declaration of real or perceived conflicts of interest before the Panel meeting; conflicted individuals exiting the meeting during the discussion of a submission where they have real or perceived conflict of interest.

4. Postdoctoral Review Panel (PRP)

Information discussed in the PRP meeting is considered Confidential Information. The PIMS PDF Panel is bound by Confidentiality. The Terms of Reference for the PIMS PDF Panel, distributed to the PRP members, contain specific instructions to the panel for maintaining Confidentiality and for managing Conflicts of Interest when they arise. These include up-front declaration of real or perceived conflicts of interest before the PRP meeting; conflicted individuals exiting the meeting during the discussion of all applications at the site where they have real or perceived conflict of interest. Panel members are asked to declare conflicts of interest with applications on their review list, and the Chair will adjust the assignments accordingly. In particular, panelists are asked to let the chair know as soon as possible if they feel they have a conflict of interest with regard to any application they have been asked to review (e.g., recent collaborator or trainee, personal connection). In addition, panelists are asked to recuse themselves from the discussion of candidates at a site in which the panelist has nominated a candidate.

5. Review and Adjudication

The Steering and Governance Committee will review and adjudicate on any conflict of interest or human resources issues which arise with respect to the PIMS Directorate and Site Directors.