ICS Policy for Interactions with Outside Entities

PURPOSE

The purpose of this Policy for Interactions with Outside Entities (this “Policy”) is to establish International Complement Society (“ICS”) standards governing the relationship between ICS committee projects and for-profit commercial providers of services or supplies that support complement research, including, but not limited to, entities that provide, develop or produce pharmaceuticals, medical devices, clinical diagnostic and/or basic/clinical research tests, clinical services or supplies, as well as intermediary organizations retained by such entities (collectively referred to herein as “Outside Entities”).

 

POLICY STATEMENT

This Policy sets forth the rules and standards by which ICS Officers, Councilors, Committee Chairs and Committee Members (collectively “ICS Representatives”) are expected to conduct themselves when dealing with Outside Entities on behalf of ICS.  Although relationships between ICS and Outside Entities can facilitate a mutually beneficial exchange of information about products or services relevant to research and patient care, these relationships can also create the potential for conflicts of interest and abuse.

 

A conflict of interest may occur when an ICS Representative has, or to a reasonable independent observer appears to have, a financial or business interest in an Outside Entity working with ICS or intending on working with ICS, the result of which could influence the ICE Representative’s judgment and compromise the person’s ability to carry out his or her fiduciary duties.

 

STANDARDS OF CONDUCT

 

  • ICS Representatives, as well as their immediate family members, shall not accept any form of personal gift, services or compensation from an Outside Entity if doing so may constitute an actual or perceived conflict of interest. This rule is not intended to affect the ability of an ICS Representative to accept consultancies for projects, sponsored research or other activities that are fully disclosed to ICS leadership and are determined to be unrelated to an ICS Representative’s role(s) in ICS.

  • If a Committee Member has a Direct Financial Interest, including but not limited to unrelated consultancies or sponsored research activities with the Outside Entity with which the Committee is interacting on projects or activities, the individual shall promptly notify the Chair of such financial interest, and recuse him/herself from activities and decisions related to that entity. A “Direct Financial Relationship” is defined herein as a relationship whereby an individual receives wages, consulting fees, honoraria or other compensation (in cash, stock or in-kind), whether paid to the individual or to another entity at the direction of the individual, for the individual’s services or expertise.

  • All Outside Entity funding for ICS projects or activities must be paid directly to ICS.

  • ICS Representatives must fully and promptly disclose all relationships with Outside Entities working with ICS to the ICS Officers or their Committee Chair at the time such conflict arises.Additionally, ICS Representatives shall complete and sign the ICS Conflict of Interest form annually.

  • Prior to starting a project with an Outside Entity, ICS and the Outside Entity shall enter into a written agreement setting forth the material terms of their relationship, including but not limited to, the separation of intellectual property (IP), ownership, confidentiality and copyright requirements.

  • Financial support of ICS projects by Outside Entities shall be disclosed to the ICS membership, and, if necessary, the public.

  • Outside Entity support is allowed for trainees provided the following conditions are met:

  1. The trainee recipient is selected through a peer review process and both the trainees and proposed training are endorsed by ICS;

  2. The trainee is not subject to any implicit or explicit quid pro quo requirements (i.e. no strings attached). Specifically, there should be no actual or perceived conflict of interest related to the financial support of trainees;

  3. The fellowship or scholarship program must be reviewed and pre-approved by ICS Officers and Council; and

  4. The funds for the training or scholarship must be paid to ICS to distribute to trainees for travel, stipends and housing.

 

This Policy supplements the standard ICS Conflict of Interest disclosure form all ICS Representatives are required to complete and sign.  This Policy is not intended to address all possible situations involving financial relationships between ICS and Outside Entities. ICS members with questions regarding relationships are encouraged to discuss the issue with ICS Officers.

 

Because each ICS Representative’s circumstances are unique, exceptions to these guidelines may be considered by the ICS Officers who will make a recommendation to the ICS Council for consideration.

                                                                                                             Adopted 04 February 2020

International Complement Society

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Contact

Sheilah Jewart

sheilah.jewart@complement.org

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