Policy Consultation – Proposed Amendments to the COI Policy (SC3)

The UBC community is invited to comment on proposed amendments to the COI Policy (SC3) and its associated Procedures (together referred to as the “Policy”). The Policy has been in place since 1992 and last underwent a comprehensive review and revision in 2005. A Policy Development Committee (the “Committee”) has been convened to develop proposed amendments to the Policy and has prepared a draft proposal. The proposed amendments:

  1. add a requirement and process for administrative staff with specific management responsibilities to submit Conflict of Interest disclosures on an annual basis through Workday to reflect practices that were implemented in 2018 at the request of the Audit Committee of the Board of Governors;
  2. broaden the Policy, which was strongly focused on the academy, to include more information about scenarios applicable to Administrative Staff;
  3. clarify that the Policy applies to students only to the extent that they are carrying out UBC research;
  4. streamline and enhance the process for addressing and investigating Conflict of Interest complaints and concerns brought before the Conflict of Interest Manager and Conflict of Interest Committee;
  5. update the Policy language (i.e., enhanced definitions, gender neutral language, etc.);
  6. enable the establishment of Rules and Guidelines as contemplated by the Regulatory Framework Policy (GA2); and
  7. improve readability (e.g. consolidated content and corresponding subject matter headings).

More specifically, the proposed amendments to the Policy include:

  1. adding a requirement to disclose Conflicts of Interest and Conflicts of Commitment by Faculty, Staff, and other UBC Persons in (Section 3. Required Disclosures) in the Procedures;
  2. a new section within the Policy (Section 4. Reporting Complaints or Concerns) that consolidates information set forth under the various sections throughout the current version of the Policy, addressing this topic in a more coherent manner;
  3. a new section within the Procedures (Section 9. Referral of Complaints or Concerns to the COI Committee) that clearly outlines the steps involved in the COI Committee investigating any complaints or concerns brought to its attention;
  4. revisions to the Procedures (Section 7. Role of the COI Committee) to more accurately reflect the responsibilities of the COI Committee;
  5. language outlining the ability of the Initial Reviewer to escalate the review of a disclosure up one level in Section 4.4 of the Procedures;
  6. a new section within the Procedures (Section 10. Outcomes Resulting from Breaches) that enhances and clarifies the actions that may be taken when a breach of the Policy or any associated Procedures or Rules has occurred;
  7. moving sections, including Definitions, Role of Initial Reviewer and Role of the COI Committee, from the current Policy to the Procedures to provide clearer direction to UBC Members by consolidating the operational applications of the Policy into the Procedures (This enables the Policy sections to be principle‐based, rather than operational.);
  8. a new section within the Procedures (Section 11. Establishing Guidelines and Rules) that articulates the role of the Responsible Executive in establishing, amending, and repealing Rules and Guidelines (This Section replaces Sections 5 and 6 in the current Policy.);
  9. simplifying the Background & Purposes and General sections, moving pertinent information to other sections of the Policy where relevant;
  10. combining and consolidating all sections related to Conflict of Interest and Conflict of Commitment so that each is addressed in a more logical order starting with Identifying Conflicts and moving through Disclosing Conflicts, Assessing Conflicts and Managing Conflicts;
  11. explicitly defining the role and responsibilities of the COI Manager in Section 6 in the Procedures; and
  12. a new section within the Procedures (Section 8. Appeals) that consolidates the various sections from the current Policy that address this topic.

For further information about the proposed amendments, please see the information package that was provided to the Board of Governors at: https://bog3.sites.olt.ubc.ca/files/2023/11/4_2023_11_Proposed-Policy-Amendment-Conflict-of-Interest-Policy-SC3.pdf

The proposed amendments are now being published for community consultation and all members of UBC’s community are encouraged to provide their comments. Please submit feedback to the Office of the University Counsel at university.counsel@ubc.ca by January 21, 2024.

Feedback received by the Office of the University Counsel from the UBC community will be provided to the members of the Committee for review and consideration. The Committee does not provide individual responses to persons submitting feedback. However, the feedback received will be summarized, along with the Committee’s response, in a Community Consultation Summary that will be included in the submission materials that are generally shared in open sessions of meetings of the responsible Board of Governor’s committee and the Board of Governors.

 

Updated on November 21, 2023 at 10:43 am