Guidance

Mitigating conflicts of interests in UK NSC work

Updated 18 March 2024

This document summarises the potential mitigations and appropriate actions the UK National Screening Committee (UK NSC) takes in response to declared conflicts of interest.

It also gives examples of direct, indirect, financial and non-financial interests and how these can be dealt with.

1. How interests should be managed

1.1 Before appointment

Potential members of the UK NSC, expert groups and specific topic groups should complete a declaration of interests form before taking up the role. UK NSC secretariat staff should discuss the form with them to ensure they are able to fulfil the role.

1.2 During term of office

Members and advisers should update declarations of interests at least annually. Any significant changes should be notified promptly so that interests can be managed appropriately by the UK NSC secretariat.

1.3 Before giving advice on specific topic

Members and advisers should be asked, and should declare, if they have any interests related to the topic, including any interests that they have not declared before.

1.4 If there is a conflict of interest

The UK NSC secretariat and the chair of the relevant group should decide how the conflict should be managed, depending on the details of the conflict.

1.5 When recommendations and decisions are published

Decisions and advice of the UK NSC, its expert groups and specific topic groups are published in reports and public recommendations. A statement should be included in published documents that explains any interests or conflicts that were declared, along with the actions taken to manage them.

2. Appropriate actions

In general, there are 3 potential actions that the UK NSC can take in response to declared interests:

2.1 No action

No action other than the process of open declaration – the person can engage in all aspects of the work.

Example

An example might be someone who works in an organisation that delivers an already approved study or programme related to the UK NSC topic.

The rationale for not excluding them is that they have specialist knowledge required for the UK NSC evidence review work. They have been transparent in declaring the interest and would be bounded by the confidentiality of the UK NSC topic discussions, so their interest has been effectively mitigated.

2.2 Partial exclusion

The person can engage in the discussions or provide advice to the group or meeting, for example due to their expert knowledge. But the individual is excluded from developing recommendations and decision-making on the topic relating to the interest.

Their involvement may be limited to answering direct questions from the committee.

Example

An example would be an individual who is participating in a study assessing treatments for a condition, but is not in receipt of any financial or in-kind benefits.

The rationale for partial exclusion is that they should be able to participate in topic discussions because of their knowledge. But their background knowledge of the study might influence them, so they should be excluded from the decision-making process.

2.3 Complete exclusion

Complete exclusion means the person can have no input to a specific topic.

Example

An example would be a clinician who is in receipt of direct personal funding from the manufacturer of the proposed treatment/intervention being considered by a screening evidence review.

The rationale for exclusion would be the clear financial conflict and the clear financial benefit they would receive following a positive screening recommendation.

3. Summary of actions

3.1 For committee and sub-group members

Interest (personal or as representative of organisations)	Mitigations
Direct financial interest	Individual(s) must leave meeting/not participate, other than in exceptional circumstances at discretion of the Chair
Indirect financial interest	Chair may allow individual(s) to participate if they consider the interest is not likely to give rise to a conflict
Non-financial direct interest	Chair to take appropriate action, seeking advice where necessary
Non-financial indirect interest	Individual(s) allowed to participate fully unless exceptional circumstances mean their inclusion would give rise to a conflict

3.2 For stakeholders participating in specific topics

Interest (personal or as representative of organisations)	Mitigations
Direct interest (financial or non-financial)	Chair to take appropriate action, seeking advice where necessary.
Indirect interest (financial or non-financial)	Individual(s) to participate fully unless exceptional circumstances mean their inclusion would give rise to a conflict.

4. Direct interests

A direct interest is when there is, or could be perceived to be, an opportunity for a person involved with the UK NSC’s work to benefit. This benefit could be a financial interest or a non-financial personal or professional interest.

5. Indirect interests

An indirect interest is when there is, or could be perceived to be, an opportunity for a third party closely associated with the person in question to benefit. This could be through a close association with another person or organisation that has a financial or non-financial interest, and could benefit from a decision the person is involved in making through their work on an advisory committee. Indirect interests can arise from people (such as close relatives, friends and associates), or employers (for example as a result of research grants or other funding).

They can also arise when an individual is appointed to represent an organisation and attend meetings or contribute to topics to speak on an organisation’s behalf. These organisational indirect interests would not usually preclude participation, but should be declared to ensure transparency about the organisation’s interest in the matter under review.

6. Financial interests

A direct financial interest is anything of monetary value, including salary, payments for services, equity interests, stocks and shares and intellectual property rights, including patents and copyrights and royalties arising from such interests.

Examples can include:

• work in the commercial sector, including a directorship or consultancy, that attracts regular or occasional payments or benefits in kind such as hospitality
• direct payment from the commercial sector to attend a meeting, conference or event, over and above funding to support reasonable travel, accommodation and attendance costs
• shareholdings or other investments in the commercial sector
• personal payment from the commercial sector to undertake research

7. Non-financial interests

A non-financial interest is when a person has a non-financial professional or personal benefit, such as increasing or maintaining their professional reputation. This can include situations where the person:

• is an advocate for a particular group or is a member of a lobbying or pressure group
• holds office or a position of authority in a professional organisation
• is actively involved in an ongoing or scheduled trial or research project
• has published a clear opinion about the topic under consideration

8. Roles and responsibilities

8.1 Stakeholders and committee members

Stakeholders and members of the UK NSC and its expert sub-groups are responsible for ensuring that all their relevant interests are declared and kept up to date through submission of the declaration of interests form.

8.2 Committee, sub-group and expert topic group chairs

Chairs of the UK NSC, its expert sub-groups and topic groups work with the UK NSC secretariat to ensure interests are declared and conflicts managed in line with guidance.

8.3 UK NSC secretariat

Secretariat staff supporting stakeholders and members are responsible for making sure declaration of interests guidance is followed and supporting its application. Secretariat staff: 

• support stakeholders and members in following the guidance, including in induction and formal training if needed
• keep up-to-date records of interests and how any conflicts are assessed and managed
• check declarations of interest in advance to identify any interests which might present a conflict for forthcoming work in which an individual may be involved, regarding the topic, matter, company or substance under consideration, and managing any conflicts in line with the guidance
• include a summary of conflicts and how they were managed in any relevant published outputs of UK NSC work