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PIDAC - Call for members Conflict of interest rules

Public Health Ontario recognizes that many external advisors may not be completely free of actual, potential or perceived conflict of interest since such external advisors may have affiliations with regulated industries, the scientific community, or special interest groups which receive funding from industry. Public Health Ontario’s rules governing conflict of interest are intended to achieve a reasonable balance between those divergent considerations and enabling Public Health Ontario to gain from the expertise of external advisors while avoiding or mitigating conflict of interest.

PIDAC committees are best served by members with differing areas of expertise and perspectives related to the achievement of the PIDAC mandate, who can provide their expertise and advice in an open, fair and objective manner.  Any situation that might interfere or be seen to interfere with an individual’s ability to meet those standards when acting as a member of any of the PIDAC committees shall be considered an actual, potential or perceived conflict of interest and shall be disclosed immediately to the President and Chief Executive Officer.

In addition to Public Health Ontario’s conflict of interest policy, PIDAC members must govern themselves by the following rules relating to conflict of interest where a conflict of interest exists for any of the following situations applicable to the member, the member’s spouse, or dependent children:

• Direct employment in or benefit from a private sector entity whose primary business may relate in any way, directly or indirectly to PIDAC-related matters, including  pharmaceutical or drug companies involved in the research and/or manufacturing of drugs or vaccines, and which carries on business with the intent or possibility of commercial gain, generating a profit, or increasing equity (“Private Sector Entity”);
• Ownership of stock, stock option or similar ownership interest in a Private Sector Entity, but excluding any interest arising solely by reason of investment in such business by a mutual, pension, or other institutional investment fund over which you do not exercise control;
• Service as a paid litigation consultant or expert witness in litigation involving a Private Sector Entity; and
• Ongoing service in an advisory or consulting role, whether paid or unpaid, to a Private Sector Entity.

PIDAC members shall take all reasonable steps to avoid any actual, potential or perceived conflict of interest and to immediately inform the President and Chief Executive Officer of circumstances that may place them in a position of conflict of interest.

All individuals expressing an interest in becoming members of a PIDAC committee must provide the President and Chief Executive Officer with a comprehensive written report disclosing:

• Any and all conflicts of interest or situations that are described above;
• All sums in excess of $1,000 received from a Private Sector Entity;
• Financial interests or ownership interests greater than $5,000 of the individual, his/her, or dependent children in Private Sector Entities or such related businesses operating in areas related to the mandate of any of the PIDAC committees; and
• Any other circumstances that could arise or that have arisen in which an individuals’ personal or private interest conflicts with, could potentially conflict with, or might reasonably be perceived to conflict with duties as a member of any of the PIDAC committees; and

Additionally, at the start of each meeting of a PIDAC committee, all members must declare any and all conflicts of interest. Members also have an ongoing obligation to submit an updated disclosure statement annually on the anniversary of their appointment or when there is any change in their affiliations.

As part of its efforts to achieving transparency regarding matters of conflict of interest, Public Health Ontario will publicly disclose all members’ affiliations on its website and to the Chief Medical Officer of Health.
Depending on the situation, the President and Chief Executive Officer will issue direction to PIDAC members with which they must comply. These include:

• Recusing oneself or withdrawing from discussion, formulating or voting on recommendations or participating in meetings; and
• In exceptional circumstances, where the extent of affiliations with Private Sector Entities or potential for intersection between such affiliations and a member’s role on a PIDAC committee is such that it becomes unmanageable, terminating an appointment.