Conflicts of Interest Policy

1. Purpose

SEA DREAM expects its funded researchers and organisations to go beyond delivering and publishing their research. We encourage engagement with others, including industry and government, to increase the impact of research outputs. However, we need to make sure these activities do not compromise the delivery of our funded research and that potential conflicts of interest are identified and managed.

2. Our policy

SEA DREAM encourages engagement with others to increase the impact of research outputs. This could involve:

• providing consultancy services

• sitting on a technology advisory board

• acting as an officer of a company

• helping your organisation to license out intellectual property (IP)

• advising on relevant government policy

Researchers and organisations (Consortium Lead and Consortium Members) must identify and effectively manage any forms of conflicts of interest so that:

• the highest ethical standards of research integrity are maintained

• the delivery of SEA DREAM-funded research is not negatively impacted

• the outputs of the research are used to try to achieve the greatest possible public benefit by improving human health

Any private benefits (such as payments or equity flowing to researchers, their lead organisations or to any commercial organisations) should be no more than incidental to the delivery of the desired public benefit

3. Scope and Definitions

A conflict of interest exists when an individual’s personal interests, those of their family, or their loyalties to another person or organisation, may (or may reasonably appear to) unduly influence or affect a decision. Conflict of interest can emerge as real, perceived, or potential conflicts. By identifying and addressing these conflicts, the organisation can make decisions that truly reflect its best interests, free from undue influence.

• Real Conflict of Interest: A real conflict of interest occurs when there is an actual, tangible situation where an individual's personal, financial, or professional interests have directly influenced, or are currently influencing, their ability to perform their duties impartially. Examples that could occur in the context of SEA DREAM include:

  • Personal Relationships: A member of SEA DREAM’s team is responsible for awarding funds to a lead consortium. This team member is an immediate family member of someone in the consortium and was unduly influenced to grant the funds to them.

  • Financial Interests: A member of Consortium Lead or Consortium Member is part of the procurement team responsible for selecting vendors for laboratory supplies. This staff member owns a stake in one of the bidding companies and influences the decision to award the contract to their own company. Another example related to intellectual property would be a conflict of interest arising if a university considered licensing SEA DREAM–funded IP to a company in which a researcher owned shares. In such a case, the conflicted researcher should not exercise any influence over the university’s decision to grant the licence or determine its terms.
     

• Perceived Conflict of Interest: A perceived conflict of interest arises when a situation appears to involve a conflict, even if there is no actual conflict. This occurs when others might reasonably believe that an individual’s interests could improperly influence their decisions or actions, affecting the trust and credibility of the organisation.

  • Political Interest: A member of SEA DREAM grantee volunteers for a political campaign in their personal time. Although the employee maintains that their political activities are separate from their professional role, colleagues and external partners might perceive a conflict, worrying that the employee’s political affiliations could affect their organisation's stance on relevant public health issues.

  • Concurrent Work: A SEA DREAM funded researcher also teaches part-time at another university. While the teaching schedule does not directly conflict with the office hours at the researcher’s main project, there may be a perception among colleagues and stakeholders that the researcher's focus and time are divided, which might affect their primary responsibilities and performance at SEA DREAM funded project.
     

• Potential Conflict of Interest: A potential conflict of interest is a situation that does not currently present a conflict of interest but could develop into one in the future if not properly managed or disclosed.

  • Interests of close associates: A Research Director is involved in the recruitment process for a new position in SEA DREAM funded research project, and one of the applicants is a close friend. While the Research Director has not yet made any hiring decisions, there is a potential conflict of interest if the Research Director's personal relationship influences the hiring decision or if it appears to others that the friend was given an unfair advantage.

  • Previous Work: A new staff joins the organisation after having worked for a company that competes for contracts with the organisation. This previous employment could lead to a potential conflict of interest if the staff is involved in procurement processes or decisions where their former employer is a bidder, whether or not they maintain any ongoing relationships.

4. What we require from the researchers

Researchers must:

• ensure that commitments to other activities do not prejudice the timely delivery of SEA DREAM-funded research

• avoid any activities that jeopardise the ethical conduct of research and/or the potential use of SEA DREAM-funded research outputs to improve human health

• disclose to their organisation as soon as possible any actual or potential conflict of interest related to the conduct of SEA DREAM-funded research and/or the potential use of resulting research outputs

In particular, in each case where a commercial entity has a potential interest in the SEA DREAM-funded research or in any directly related fields, researchers must inform their organisation and comply with their organisation’s requirements:

• before they act as a consultant or adviser to that commercial entity

• before they enter into any research collaboration, sponsorship or other funding agreement with that commercial entity

• before accepting any directorship at that commercial entity

• if the researcher, or any immediate family member, is employed by or owns shares in, that commercial entity

5. What we require from the organisations

The organisations (both Consortium Lead and Members) must:

• Have a formal policy to identify and manage potential conflicts of interest.
• Assess all potential conflicts of interest involving SEA DREAM-funded researchers, their research projects or outputs, to determine if the conflict is material and if so, how it should be managed.
• Ensure that conflicts of interest and their management do not lead to breaching any part of the award letter and grant conditions agreed between SEA DREAM and grantees. In particular, you must ensure that relationships and transactions promote public benefit (with only incidental private benefits) and that the use of SEA DREAM-funded research outputs comply with our Data, Software and Materials Management and Sharing Policy and our Intellectual Property Policy.
• Ensure that researcher relationships and activities that might create potential conflicts (such as consultancies, advisory roles, board memberships and material transfers) are set out in formal written agreements which protect SEA DREAM’s interests in the conduct of the research and the potential use of the outputs to improve human health.
• Ensure that agreements transferring ownership of, or licensing rights to, any SEA DREAM-funded IP (including granting access to unpublished data or conclusions) comply with the terms of the funding from SEA DREAM, such as Universal and Specific Grant Conditions and SEA DREAM’s Intellectual Property Policy. These agreements must be negotiated as arm’s length transactions, especially where SEA DREAM-funded IP is being assigned or licensed to a researcher or to a commercial entity with which the researcher has a relationship.

In addition, organisations funded by SEA DREAM are expected to establish an internal audit system to identify potential conflicts of interest within their operations, as well as a training or awareness-raising program for staff, delivered during onboarding and at regular intervals (e.g. annually).

6. Breach of Our Policy

Where there has been a breach, or potential breach, of this policy or the organisation’s own policy on conflicts of interest, we should be informed as soon as possible about the issues identified and the actions taken. Any breaches should be handled in accordance with our research misconduct policy.

 

SEA DREAM-funded researchers and organisations must provide to us on request:

• copies of the organisation’s conflicts of interest policy, monitoring procedures and decisions

• current information about consultancies, advisory roles, directorships and other relationships of relevance to this policy, together with details of any relevant income and shareholdings

• all other relevant information or documentation required for us to review the management of a conflict of interest

The concerned individual must also temporarily withdraw from participation in any associated decision/review processes or relevant work for which the alleged conflict is being investigated. This makes sure that the investigation can proceed without bias or influence and no potential further conflicts of interest during the investigation.

7. Sanctions

While organisations are expected to take appropriate disciplinary action in accordance with their own policies, SEA DREAM may also impose sanctions, depending on the significance of the conflict and the extent of any benefits gained. If a funded researcher or organisation breaches this policy, we will consider this to be a breach of our Grant Conditions and we may suspend or terminate the relevant award. We may also audit the operational processes of the concerned organisation(s) more widely.