Conflicts of interest policy for individuals involved in research funding
1.1.1 This policy applies to everyone who is involved in providing strategic advice or making decisions connected with the review of scientific research or research resources by Breast Cancer Now. It includes all funding committees and panels and other individuals involved in the application process, including external reviewers and Tissue Bank advisers, collectively known as ‘Advisers’.
1.1.2 All relevant individuals have a responsibility to be aware of the potential for a conflict of interest. All conflicts of interest, whether actual or potential, should be declared at the earliest possible opportunity.
1.1.3 This conflicts of interest policy is managed by Breast Cancer Now’s research funding staff, including the Director of Research, collectively here referred to as ‘the Secretariat.’
1.1.4 Breast Cancer Now has set out a Code of Conduct for individuals involved in research funding (see below).
2. What is a conflict of interest?
2.1 A conflict of interest is any situation in which personal interests or loyalties could, or may, prevent the person with the conflict from making a decision in the best interests of the Charity.
2.2 External conflicts of interest
2.2.1 Interests which should be disclosed by such individuals include:
Financial Interests including equity interests in enterprises with involvement in pharmaceuticals, healthcare, biotech or related areas, or in any other enterprise that may have a real or perceived interest in the work of the Charity. Third party investments (e.g. ISAs) are exempt from this.
Loyalties including a personal connection or duty to another person or organisation including a past employer, past student, family member, friend, close colleague or collaborator.
2.3 Conflicting interests relevant to the provision of advice
2.3.1 Breast Cancer Now seeks impartial scientific advice on research proposals and access to research resources, - and as such an individual should advise if they have a connection in any of the following ways:
- Are an applicant, co-applicant or collaborator on a proposal to Breast Cancer Now in the same funding round;
- Belongs to the same institution as an applicant or co-applicant;
- Have co-authored a paper with the lead applicant(s) in the last five years;
- A named collaborator; or a recent collaborator with the listed main applicant and/or co-applicant(s) of a grant application;
- A relative of one of the grant applicants (“relative” for this purpose includes, but is not limited to, spouse or partner (current or past), children, siblings and parents);
- A personal friend of one of the applicants;
- A business partner of one of the applicants; or a member or employee of the same university, or other institution, as the applicant or co-applicant; • Has a direct or indirect financial interest with an application being considered;
- Has a competitive interest with an application being considered or
- Is aware of any other issues (whether academic, scientific, financial, business, personal or otherwise) that might give rise to a conflicting interest
2.3.2 All Advisers should be aware that they are being approached as an individual with specific expertise and not as a representative of any organisation by which they are employed, or with which they have significant contracts or connections.
2.3.3 An Adviser must maintain confidentiality and should not misuse information gained in the course of their role for personal gain or use their position to promote their personal interests. Advisers will be asked to sign a Confidentiality Agreement when they join a Committee/or Group.
2.4 Declaration of interests
2.4.1 Upon appointment, a Committee member shall be asked to complete a declaration of interests form setting out any conflicting interests. These Interests will be added to Breast Cancer Now’s Register of Interests of Scientific Advisers. This declaration shall include details of remuneration for any post mentioned in clause 2.2.
2.4.2 Committee Members will be asked to update their Declaration of Interests annually.
2.4.3 External reviewers shall be asked to consider, and consequently declare, any conflicts of interest identified when they are initially contacted to provide a peer review.
3. Managing conflicts of interests
3.1 Breast Cancer Now recognises that the majority of conflicts or potential conflicts will relate to a particular issue and as such will not present any long term restrictions on an individual’s ability to work for the charity or to sit on its committees.
3.2 In a small number of cases, major conflicts of interest may arise which compromise an individual’s ability to continue in their position within the charity. Where such a situation relates to a member of a funding committee the matter will be discussed by the Chair of the committee and the Director of Research.
3.3 The Secretariat, with reference to the Chair of the Committee as appropriate, shall decide what action should be taken to deal with the Conflicting Interest. This may include:
3.3.1 Automatic exclusion from participation in funding decisions
Where a Committee member is an applicant or co-applicant on a grant application, they must declare an interest and will not be party to any information connected with assessment of the application. Review documentation will not be sent to the member and they must retire from the meeting when their application is assessed. If the Chair is the lead applicant they will be asked to absent themselves from the entire meeting and the Deputy-Chair will assume the Chair’s role.
3.3.2 Exclusion at Breast Cancer Now’s discretion
Individuals may be excluded from Committee discussions at the discretion of Breast Cancer Now in a number of circumstances including if they:
- Are a direct competitor of the applicant or
- Have acted as an external reviewer or on a committee or panel in respect of a proposal at a time when this was being considered by another funding body.
3.4 The Secretariat or, as appropriate, the Secretariat in consultation with the Chair, or Deputy Chair (if the Chair is conflicted) will determine whether the individual should:
- Be permitted to provide their assessment as an external reviewer;
- Be permitted to take full part in the meeting;
- Be permitted to comment on the application and participate in discussions but not lead on presenting the application to the committee;
- Be permitted to comment on the application and participate in discussions but not take part in the scoring or decision-making;
- Absent himself or herself from the relevant part of the meeting.
3.5 The Secretariat will bring to the Chair’s attention all relevant information concerning any form of connection between an application and a member of the committee.
4. Confidentiality and transparency
4.1 Details of funded grants, applications, meeting papers and related correspondence and the names of external referees are strictly confidential and should not be discussed with persons outside of the Committee and the Secretariat. Advisers will also undertake to keep all documents confidential and dispose of them securely.
4.2 Where Advisers feel it necessary to discuss a proposal with another member, or a specialist in the relevant field, prior to the meeting, this should be declared at the meeting.
4.3 If an Adviser is approached by an applicant for technical advice on an application in his or her area of specialisation, the individual may provide such advice but must disclose this fact to the Secretariat of the Committee. The Adviser may be excluded from all or part of the meeting at which the application is considered.
4.4 If an Adviser is approached by an applicant once a proposal has been submitted, the Adviser must not engage in discussion and disclose this incident to the Secretariat of the Committee.
4.5 If Advisers consider their specialist advice could enhance the conduct of funded research, or future submissions, they should inform the Secretariat who will provide their contact details to the applicants.
5. Raising concerns about the conflicts of interests of other individuals
5.1 An individual who is concerned about another individual’s potential or actual conflict of interest should raise the matter as set out below: o Issues concerning a member of the Committee should be raised with the Secretariat of the Committee o Issues concerning Breast Cancer Now staff should be raised with the Director of Research
6. Tissue Bank Groups
Tissue Bank committees and groups are bound under this agreement to work as set out in the relevant Terms of Reference.
Code of Conduct for individuals involved in research funding
Purpose: The purpose of this document is to set out what is expected of individuals connected with Breast Cancer Now funding, including Committee Members and Scientific Advisers.
Breast Cancer Now relies extensively on the independent advice and support of experts as it makes decisions about funding and its research strategy. Advisers and Committee Members must therefore agree to:
- Objectively and impartially contribute to the development of scientific policy and the assessment of funding applications;
- Commit to full participation in meetings, listening to others and contributing positively to the discussions;
- Examine and challenge, if necessary, the assumptions on which scientific advice is formulated and
- Share the general responsibility of considering the wider relevance of their decisions to the field of breast cancer research.
In doing this, Advisers and Committee members should:
- Strive at attend all meetings or provide apologies if unable to do so;
- Prepare for the meeting by reading the paperwork in advance and undertaking any due diligence;
- Contact the Committee Secretariat if you have any uncertainty of what is expected of you;
- Respect confidentiality around paperwork and any discussions at meetings. Specifically, securely store, and do not disseminate, any paperwork (whether in hard copy or sent electronically) and securely destroy when no longer required;
- Refrain from discussing any aspects of the deliberations or recommendations of Advisers or Committees directly with applicants. Instead, if appropriate, Breast Cancer Now staff will provide verbal or written feedback according to current practices;
- Declare any conflicts of interest as soon as these become apparent to allow Breast Cancer Now staff to advise on any necessary action(s);
- Complete the annual Declaration of Interests in a timely manner.
- Breast Cancer Now is committed to ensuring its research findings are openly and freely available to everyone;
- This policy applies to all research outputs supported in whole, or in part, by Breast Cancer Now funding;
- Breast Cancer Now is a funder of Europe PubMed Central (Europe PMC), a searchable literature repository accessible worldwide;
- All publications arising from funded research must be deposited in Europe PMC as soon as possible, and no later than 12 months following publication;
- There are no additional costs to grant holders for depositing a manuscript in Europe PMC;
- Current arrangements for the reimbursement of open access Article Processing Charges (APCs) in conjunction with the Charity Open Access Fund (COAF) will end in September 2016;
- Breast Cancer Now continues to encourage publications in open access journals and open access format and fees can be paid using any underspend on existing grants.
Why is Open Access important?
Breast Cancer Now’s mission is to fund breast cancer research and we believe that if we all act now, by 2050, everyone who develops breast cancer will live. We want our research to have the maximum impact possible and believe this can be achieved by having our research findings openly and freely available to everyone.
Open Access (OA) provides unrestricted online access to research findings allowing them to be downloaded, read, cited and used by individuals who do not have access to scientific journals through a personal or institutional subscription. This helps accelerate progress, promote innovation and ultimately should allow the charity’s objectives to be achieved more quickly.
Models of Open Access
There are several open access models.
i. The ‘Gold’ model where the final published PDF of a research article is made available without the need for a journal subscription. A charge of between £500 and £2500 is made for each article.
ii. The ‘Green’ model where a copy of the accepted manuscript is deposited in an open access repository at no cost. Access to the article may be subject to a publisher’s embargo period (usually 6-12 months)1 but self-archiving is possible.
1 Information on the OA positions and embargo periods applied by different open access publishers can be found on the SHERPA/ Romeo website.
Europe PMC membership
Breast Cancer Now is a funder of Europe PMC, an electronic repository allowing worldwide access to patents, National Health Service guidelines and other records as well as published research manuscripts. The repository also permits text-mining of full articles through advanced key word searches. Importantly, Europe PMC permits Breast Cancer Now funded grant holders to deposit their manuscripts through the ‘Green’ route at no additional cost.
What does the policy mean for Breast Cancer Now grant holders?
- The policy applies to all researchers funded wholly, or in part, by Breast Cancer Now;
- All grant holders must deposit their manuscripts in Europe PMC as soon as possible, and no later than 12 months following publication;
- Previous arrangements for support of Open Access costs through the Charity Open Access Fund (COAF) will end in September 2016. From this date the charity will support the ‘Green’ Model of OA publishing, allowing grant holders to use any underspend on their grants towards open access charges;
- Many journals automatically deposit papers in Europe PMC if the funder is a member of Europe PMC. If such a service is not provided, grant holders will need to self-archive using Europe PMC plus.
Why has Breast Cancer now altered its Open Access policy?
After a two year pilot period, Breast Cancer Now recently reviewed its support of, and funding for, a ‘Gold’ open access (OA) model. Our review suggests that continued support for the ‘Gold’ model would cost Breast Cancer Now a significant amount of money per annum. Based on the current developments in a rapidly evolving open access landscape, the charity has decided to revert to promoting the ‘Green’ OA model at this time. We will continue to monitor changes in this landscape with the goal of continuing to provide open and unrestricted access to our publications at a reasonable economic cost.
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Breast Cancer Now is a member of the Association of Medical Research Charities (AMRC), which represents the leading medical and health research charities in the UK. We support the principle of using animals in research when it is necessary to advance understanding of health and disease and to develop new treatments. This research only takes place where there is no alternative available. We support the AMRC statement on the Use of Animals in Medical Research. This document should therefore be read in conjunction with the AMRC Statement.
What we expect from our researchers
If you receive funding from Breast Cancer Now, please remember the following:
- Your grant must not be used for any research on animals which has not been approved and set out in the grant application.
- Where possible you should adopt procedures and techniques which avoid the use of animals. Where this is not possible you should use the minimum number of animals considered necessary to achieving a valid result in any experiment. You should adhere to the principles of the 3Rs by using the minimum number of animals possible and causing the least suffering. Adhering to these principles may involve the use of animals of a higher quality or species.
- You must comply with all applicable laws, regulations and guidelines, including but not limited to the Animals (Scientific Procedures) Act 1986, relating to the use and handling of live animals in relation to the Project.
- You must not commence any activities under the Project that require the use of animals until all the necessary licenses and certificates have been obtained.
What our researchers can expect from us
- When communicating about your work, such as on our website or in press releases, we may mention that the research involves animal work, unless we are specifically requested not to.
- We will share data on how much animal research we fund with the AMRC.
- Communicating about work which involves the use of animals can be sensitive, and there are some that may seek to misuse information about your research. We can help you talk about your work in the most effective way. If you are unsure of how to best communicate your animal research to the public, please get in contact with the Research Communications team for advice and support.
In order to support the dissemination of Breast Cancer Now-funded work within the scientific community, Breast Cancer Now may supplement your response-mode grant budget with an additional ‘conference attendance’ award. These funds can only be used for the purpose of conference attendance and travel, and cannot be used to supplement any other part of your budget. Claims must meet specific criteria detailed below.
In order to qualify for reimbursement, the attendee must present Breast Cancer Now funded work, either in the form of a poster or oral presentation. The charity will refund costs on receipt of an invoice accompanied by a completed expenditure breakdown form, and will require an abstract to be submitted.
You can claim for up to £1,900 for the costs of travel, registration and accommodation for conferences during the lifetime of the award. We expect that, where possible, the conference travel budget is used to fund the named researcher on the grant. This will be detailed in your Grant Award Letter.
You can claim for up to £1,900 for the costs of travel, registration and accommodation for conferences during the lifetime of the award. As the conference travel budget should form part of the student’s career development plan the charity will only reimburse travel costs for the named researcher. PhD students may also use the award for travel for training purposes (in new techniques, for example). This will be detailed in your Grant Award Letter.
You can claim for up to £4500 for travel, registration and accommodation for conference during the lifetime of the award. This will be detailed in your Grant Award Letter.
No conference travel costs are awarded for pilot grants.
Guidelines for booking conference travel
Breast Cancer Now receives all of its funding through charitable giving. As such it is necessary that costs are minimised wherever possible, and we ask that the following guidelines are observed when booking travel:
- Travel and/or accommodation should be arranged at least two weeks in advance
- Where relevant, travel should be standard/economy class (except where cheaper options are available)
- Please note that on many occasions two single tickets may be cheaper than a return
- Breast Cancer Now reserves the right to refuse payments for any costs it deems to be unreasonable
- Breast Cancer Now will only reimburse the travel costs for one attendee per presentation for each conference. Other attendees, including co-applicants, collaborators and unnamed researchers, may not claim from this budget
- The Conference Travel Budget is available throughout the duration of the grant
Breast Cancer Now has an obligation to make available information about the work that it funds. This policy covers the expectations and responsibilities of Breast Cancer Now-funded researchers when publishing and publicising your work. This policy also sets out what Breast Cancer Now expects from its researchers in terms of its fundraising and engagement initiatives.
Acknowledging Breast Cancer Now
In any oral or written report or poster presentation of results or otherwise relating to the Research, the author must acknowledge the support of Breast Cancer Now and, where possible, display the Breast Cancer Now logo. Presentations templates and our logo can be requested from the Research Funding team at firstname.lastname@example.org.
All references to Breast Cancer Now funded work placed on websites, electronic bulletin boards and similar must state clearly that the work is funded by Breast Cancer Now and, where practical, should include a link to Breast Cancer Now’s website, www.breastcancernow.org.
Where possible, Breast Cancer Now’s logo should be visible in laboratories, offices or other locations where funding is received from Breast Cancer Now. This is expected of our longterm grants.
Please get in touch with us at email@example.com for further information on how to comply.
Publishing your work
Breast Cancer Now requires researchers to disseminate the results of the research that it funds in the usual manner, for example by publication and by presenting at meetings. Breast Cancer Now may sometimes request the publication to be delayed to meet reasonable requirements for the protection of Intellectual Property Rights, fundraising and other matters, but this will not be applied unnecessarily.
Grant Holders must provide Breast Cancer Now with details of all publications arising from their Breast Cancer Now Research Grant, whether wholly or partly funded (email firstname.lastname@example.org), and should supply a copy of any such publications.
These details should be provided at the time of submitting the paper for publication. Grant Holders should then update Breast Cancer Now as the paper is accepted and then published. This ensures that Breast Cancer Now is kept fully informed of all results entering the public domain and that there is sufficient notice to arrange any publicity.
It is a condition of funding that Breast Cancer Now Grant Holders to deposit an electronic copy of peer-reviewed, published papers arising from their Breast Cancer Now funded work in the Europe PubMed Central database as soon as possible and no later than 12 months from publication date. Please refer to Breast Cancer Now’s Policy on Open Access for details on how to comply.
The following standard format is required for inclusion in an appropriate place within the funding or acknowledgement section of any publication:
‘This work was supported by Breast Cancer Now [Grant Ref no:[xxx]’.
The unique project grant reference number can be found on the Grant Holders Award Letter e.g. 2018NovPR102. Where appropriate, you should indicate where individuals hold specific, named fellowships.
Publicising your work
In order to safeguard future voluntary income it is essential that Breast Cancer Now is widely known and respected among the scientific community, the media and among fundraisers and the general public. We are therefore keen to ensure that all opportunities to promote Breast Cancer Now are fully exploited and that the generosity of Breast Cancer Now’s supporters is recognised across all Breast Cancer Now’s activities and funded research. Both you and your Host Institution must co-operate with Breast Cancer Now over any publicity or fundraising activity arising from Breast Cancer Now-funded research.
In order to support our researchers in the dissemination of their research, we have a press office and research communications team that can help you to promote your research findings. We will work with you to help publicise your work in the local, national or international media, and to public or targeted scientific audiences, including online and in social media. We want to give you appropriate support and will work directly with you and your Host institution to coordinate media promotion. To do so effectively we must know about your results as soon as possible, and in advance of publication.
Where Breast Cancer Now is the main funder of the research, Breast Cancer Now reserves the right to lead on publicity. This constitutes first-refusal and does not mean that every piece of research will be press released.
In all cases, including where Breast Cancer Now is not the main funder, Grant Holders and the Host Institution are required to contact Breast Cancer Now’s Press Office (email email@example.com) prior to any publicity releases about Breast Cancer Now-funded research. Where Breast Cancer Now is the main or a joint-lead funder this should be prior to a release being drafted.
When speaking publicly about research funded by Breast Cancer Now, and particularly when speaking to representatives of the media, researchers should ensure that they are recognised as a Breast Cancer Now funded scientist. However, researchers should not speak to the media as a ‘Breast Cancer Now funded scientist’ without prior consultation with the Breast Cancer Now Press Office. If Breast Cancer Now asks a researcher to act as a spokesperson, we will provide briefings and support as needed.
Breast Cancer Now reserves the right to use data or other material from research that it funds as part of its fundraising or publicity activities, and as part of submissions to the National Cancer Research Institute (NCRI).
In publicity work, Breast Cancer Now will adhere to any embargo time and date placed on a publication by the journal in which it is being published.
Engagement with the breast cancer community, fundraisers and our supporters
We aim to bring our research and breast cancer community together whenever we can. We are proud of the research that we fund and are keen to show our supporters how their donations are used. Breast Cancer Now expects its researchers to contribute to its fundraising and engagement initiatives, local community work and national campaigns when asked to do so. Contribution could be by hosting lab tours, speaking at fundraising events, volunteering or actively participating in events. These visits may include Breast Cancer Now’s staff, Trustees, Science Strategy Committee members, technology transfer agents, fundraisers, spokespeople, local politicians and supporters. Requests will be reasonable and appropriate and will be agreed with the Grant Holder in advance.
For more details about how you can volunteer and participate in events please see www.breastcancernow.org/get-involved. If you are happy to participate from time to time in these kind of events, you can email firstname.lastname@example.org, detailing how you would like to get involved and whether you have experience of talking to a lay audience.
The public activity described above can sometimes generate publicity. Where possible Breast Cancer Now will contact you to make you aware of this beforehand; however, this is something that cannot always be foreseen.
Breast Cancer Now will, from time to time, communicate with its grant holders by way of a biannual newsletters which will provide information on grant funding, science updates and other relevant articles. Breast Cancer Now may also communicate details of relevant upcoming conferences and courses.
If you do not wish to receive our Researcher eNewsletters, please email email@example.com.
Supporting Breast Cancer Now’s peer review process
Grant Holders are expected to respond positively and punctually to requests to peer review Breast Cancer Now Grant applications.