Conflicts of Interest (COI)
The present guidance for members of evaluation bodies shows how to handle COI.
Ensuring an impartial and quality-driven evaluation of each grant application is the SNSF’s main mission and independence is key to the SNSF’s reputation. At the same time, the SNSF was set up to enable self-governance, with active scientists as evaluators of other scientists. Despite the tension between independence and the interconnected nature of research, it is possible to handle COI pursuant to the legal requirements.
Why does the SNSF have special obligations regarding COI-handling?
The SNSF performs a federal government mandate using federal funds. Each grant applicant is entitled to an impartial procedure as guaranteed by art. 29 of the Federal Constitution and art. 10 of the Federal Administrative Procedure Act (APA).
What is a COI?
Legally, a COI is essentially defined as an “objective appearance of partiality”. This appearance exists if an external observer would have reasonable grounds to think that an evaluation body member might not be impartial. This also encompasses potential partiality.
It is immaterial
- whether the person concerned is really subject to partiality,
- whether the COI alters the person’s behaviour,
- whether the COI has an impact on the outcome of the grant evaluation.
What precisely should you do in the event of COI?
Always ask yourself whether an external observer could reasonably perceive you as lacking impartiality with regard to an application.
Disclose your COI spontaneously, i.e. without being asked.
Remind other members of their COI duties in case they might have forgotten.
A person with COI must recuse him/herself, i.e. be excluded from the whole evaluation process:
- He/she must not participate in or listen to discussions regarding the application concerned.
- He/she must not access any files related to the application concerned.
To whom do obligations apply in the event of COI?
All persons who participate at any stage in the grant evaluation procedure are subject to the same recusal obligations in the event of COI. Consequently, these obligations apply equally to evaluation body members (including advising or observing members), external reviewers and SNSF staff.
The present sections show the possible COI types and practical examples.
Do you have close family or personal links with an applicant/project team member?
e.g.: close personal friendship, special personal enmity, close relatives, marriage, cohabitation
You can safely be assumed to remain impartial if (non-exhaustive examples):
- you have occasionally met one of the team members at scientific conferences.
- you did your undergraduate studies at the same faculty as a team member.
- you are interested in the work of a team member and read all his/her publications.
You cannot be assumed to be impartial if (non-exhaustive examples):
- you are an uncle/aunt of a team member.
- you are an in-law of a team member.
- there is a close and/or long-lasting friendship between you and a team member.
Are you in a current, recent (past 5 years) or planned professional, scientific or institutional collaboration with an applicant/project team member?
e. g.:
- acting as co-applicant or project partner in a collaboration (paid or unpaid),
- working in a closely associated organisational unit,
- publishing jointly (field specifics should be taken into account).
Are you in the same institution?
The decisive factor is the size and structure of the institution and of organisational units, and thus whether you have sufficient distance from the team members.
You can safely be assumed to remain impartial if (non-exhaustive examples):
- you work at the same institution but are not in contact with a team member (e.g. no common tasks,).
- you have not worked at the same institution in the past 5 years.
You cannot be assumed to be impartial if (non-exhaustive examples):
- you work at the same institution and are involved in common tasks.
- you regularly interact with a team member.
Special examples applicable to the Careers Division regarding the same institution
You cannot be assumed to be impartial if (non-exhaustive examples):
- you are active at the proposed host institute/department (that the applicant has applied for).
- you are active at a current institute/department (where the applicant was or is currently located)
- AND have/had regular contact with the applicant.
Do you have joint publications?
You can safely be assumed to remain impartial if (non-exhaustive examples):
- you have published together with a team member, but only in a loose collaboration
- (e.g. large number of co-authors, no meetings, only a few e-mail exchanges)
You cannot be assumed to be impartial if (non-exhaustive examples):
- you have published together in close collaboration with a team member
- (e.g. small number of co-authors, regular meetings) in the past 5 years
Are you in direct competition with a team member and/or the project?
i.e. you could have a vested interest in the outcome of the grant, or you could directly benefit from the research ideas.
You can safely be assumed to remain impartial if (non-exhaustive examples):
- you are working in the same field as a team member.
- your work used to focus on a very similar topic in the past,
- but your research interests have changed since then.
You cannot be assumed to be impartial if (non-exhaustive examples):
- your own career will likely be influenced by the outcome of the project.
- you are preparing a proposal or implementing a project on the same research topic.
Do you have any other vested interest (e. g. financial interests) in the specific research project or are there any other reasons for an outside observer to reasonably suspect partiality?
You cannot be assumed to be impartial if (non-exhaustive examples):
- you could benefit from or be disadvantaged by the outcome of the project.
- you advised the applicant(s) to file the application in question.
- you have financial/commercial ties (e.g. consultancy, ownership of shares or patents/copyrights/royalties; employment) that could give rise to a perception of partiality.
- you are a member of an interest group whose central concern is promoted or criticised by the proposed project (e.g. if you were asked to review a project about end-of-life measures but are a member of an association against euthanasia).
- you have any other reason that might fundamentally call an impartial evaluation into question.
Did you know?
“COI have nothing to do with (fair or unfair) intentions. They are about circumstances which are incompatible with evaluating specific grants.”
“Extra-strict evaluation cannot compensate for a COI.”
“Not everything is a COI. The examples above provide an understanding of the intensity/closeness of a relationship or interest that would lead to an objective appearance of partiality.”
“Indirect COI are also relevant, e.g. a close relative of yours is in direct competition with an applicant.”
“A COI can arise if several elements which, considered individually, would not constitute a COI occur cumulatively in the same case.”
You can read more about COI in the SNSF COI Guidelines (PDF).