In all their activities, members of the EFNA Board and consultants/staff members will adhere to the principle of transparency and declare any potential conflicts of interests.
Declarations of interests
Board members and consultants/staff members are required to declare all interests annually – or as required. Similarly, candidates to the Board shall fill in a declaration of interests together with their nomination form.
In a declaration of interests, they shall list:
- All other organisations they are members of, which could give rise to a conflict of interest,
- All projects and activities they are involved in, which could give rise to a conflict of interest,
- All personal circumstances, which could give rise to a conflict of interest,
- All financial, commercial or business interests they or a close member of their family (spouse, children, parents) have, which could give rise to a conflict of interest,
- All contacts with pharmaceutical companies, which could give rise to a conflict of interest.
- All governmental positions (paid or unpaid) they have, which could give rise to a conflict of interest.
Procedure for disclosing conflicts of interest during meetings/discussions
As well as completing the annual disclosure form, there may be occasions when Board, staff, consultants, etc. need to declare a conflict of interest.
For example, when agenda items arise – where a participant has a potential conflict of interest – this person must declare such a conflict in advance. Also, a Board or consultant/staff member may raise the issue of a potential conflict of interest of another participant for any agenda item.
The Board shall assess any potential conflict of interest and will ask the relevant person to leave the room for the duration of the discussion. The Board will take its decisions with a simple majority and its decisions are final. All such decisions will be minuted.
The Board may decide that:
- a) There is no conflict of interest warranting any remedy and the meeting will continue in the presence of the person who disclosed the potential conflict of interest.
- b) There is a conflict of interest and the meeting will continue in the absence of the person in question for the duration of the agenda item. Furthermore, Board members may not take part in any votes relating to the agenda item in question.
Procedure for non-disclosed conflicts of interest
If Board members, staff members or consultants fail to declare their interests which become apparent later, the Board shall meet in order to discuss the consequences to be given to such non-disclosure. The Board member, staff member or consultant in question may be asked to participate in part of the meeting in order to answer any questions the Board may have. The deliberations on possible consequences will be done in the absence of the Board member, staff member or consultant in question. In such cases, the Board may decide on a course of action and, depending on the gravity of the non-disclosure, may:
- Void any decisions taken which may have been affected by the non-disclosure,
- Disqualify the Board member or
- Take any other legal or disciplinary actions necessary.
Decisions to void decisions affected by a non-disclosed conflict of interest are taken by simple majority, but decisions to disqualify a Board member require a two thirds majority of Board members present or represented. All such decisions are minuted and may be forwarded to all member organisations for information on a decision by the Board.