RELATED DOCUMENTS
Principal Investigators Policy; Authorship and Publication of Results Policy; Research Integrity
Policy; Review of Alleged Research Misconduct Procedure, Committee on Publication Ethics
(COPE) guidelines.
SECTION 1 POLICY STATEMENT
1.1. The University Mohammed VI Polytechnic (UM6P) incites its investigators to participate in research activities while upholding the utmost ethical standards.
1.2. Having a conflict of interest does not inherently imply improper conduct of research, but
1.3. Identifying, addressing, and mitigating conflicts of interest is imperative to prevent any compromise to the research integrity.
1.4.Notwithstanding the above, UM6P recognizes that prominent scholars attract many opportunities to speak, consult, and otherwise engage with outside organizations.
SECTION 2 SCOPE AND APPLICABILITY
2.1. This policy applies to all investigators responsible for research activities at the university.
SECTION 3 PURPOSE
3.1.The purpose of this policy is to ensure investigators’ awareness regarding potential conflicts of interest and to establish a procedure for the proper management or prevention of such
conflicts, whether they are actual, potential, or apparent.
3.2. The premise of this policy is that each member of the UM6P research community is obliged to prioritize the best interests of the university and should not allow external interests to disrupt this commitment.
SECTION 4 DEFINITIONS
4.1. Research Conflict of interest (RCOI) refers to a situation in which financial or other personal considerations may compromise or appear to compromise professional judgment or integrity in the conduct or reporting of research. RCOI include but not limited to:
– Unfair access by an outside party to UM6P laboratories;
– The procurement of research items from a specific vendor solely due to personal
acquaintance or prior knowledge;
– Accepting or soliciting a gift, favor, money, or service that is intended to, or might
appear to, influence the researcher’s decision-making or research conduct;
– Having a financial interest in companies that are relevant to his or her research;
– Pressing to publish results that are consistent with prevailing theories or the preferences of funding sources, rather than presenting objective results;
– Prohibiting the publication of the results that are not consistent with prevailing theories or the presences of funding sources;
– Accepting, agreeing to accept, or soliciting money or other tangible or intangible benefits in exchange for the researcher’s favorable findings or recommendations; or
– Favoring students or colleagues when evaluating research.
– Research support (including salaries, equipment, supplies, and other expenses) by organizations that may gain or lose financially through this publication.
– A specific role for the funder in the conceptualization, design, data collection, analysis, decision to publish, or preparation of the manuscript.
4.2. Disclosure refers to an investigator’s disclosure of interests related to his or her institutional responsibilities.
4.3. Investigator includes the principal investigator as well as any other individual, whether faculty, staff, or student and regardless of title or position, who is responsible for the design, conduct, or reporting of research.
4.4. Conflict Management Plan refers to an agreement that sets limits and restrictions to address a RCOI to ensure that the design, conduct, and reporting of research are free from
bias or the appearance of bias.
4.5. Research refers to any systematic investigation, including research development, testing, reporting, publishing, study, evaluation, demonstration, or survey designed to develop or
contribute to generalizable knowledge or specific knowledge by establishing, discovering, developing, elucidating, or confirming information about, or the underlying mechanism relating to the matters to be studied. The term encompasses basic research, applied research, and research training activities.
SECTION 5 PROVISIONS AND GUIDELINES
General Provisions
5.1. Investigators should promptly disclose and manage any potential or actual conflicts of interest that may arise in their professional and research activities (see 5.7).
5.2.Investigators should avoid situations where external interests compromise their objectivity.
Roles and Responsibilities
5.3. Each investigator needs to follow the university’s rules about research ethics (see Research Integrity Policy). This includes being open and vigilant about any situation that might cause a real or apparent conflict of interest.
5.4.Each investigator is responsible for recognizing and disclosing to the other co-investigators any financial or non-financial conflicts of interest that might bias their work (see
Authorship and Publication of Results Policy).
5.5.In sponsored research, UM6P promotes fair and unbiased research. The university establishes rules to ensure that the research design, conduct, and reporting remain free from
financial interests or any perception of bias. Consequently, investigators within the UM6P must adhere to all university policies and procedures concerning conflicts of interest.
Declaring conflicts of interest
5.6.Each investigator is required to declare via e-mail any competing interests to the Head of department within a reasonable period (generally 30 days) following the date on which the
RCOI is acquired or arises.
5.7.The disclosure should (Appendix 1:):
• delineate how the RCOI is related, or not, to the investigator’s institutional responsibilities at UM6P;
• the identity of the external entity, this should include the entity’s name, nature of business, and any other relevant details;
• his/her current or pending relationship with the external entity;
• the purpose and the duration; and
• a proposal outlining how the conflict of interest could be effectively managed.
5.8. Investigators must inform any co-investigators participating in the planning, execution, or documentation of externally sponsored research projects about his or her obligation to fill
out a disclosure form.
5.9.Investigators are obligated to meet reporting requirements as stipulated in their funding agreements or established by external sponsors and entities.
Review, Evaluation, and Resolution
5.10. The Head of Department will review the investigator’s disclosure and determine whether the RCOI is related to the research.
5.11. The Head of Department submits the disclosure to the Dean of Faculty/School within 7 working days.
5.12. The Dean of Faculty determines if there is a RCOI and recommendations to the Research Committee, whether the RCOI can be managed.
5.13. The Dean of Faculty/School submits the plan to Research Committee within 7 working days.
5.14. Research Committee makes the final determination of RCOI and whether it can be managed.
5.15. Research Committee notifies investigator of decisions and next steps.
5.16. The Research Committee will carry out an assessment and a decision will be made (within 30 days) on whether the investigator should eliminate or manage the RCOI as
deemed fitting.
5.17. RCOI assessment take into account:
• its effect on the design, conduct, or reporting of the research conducted on behalf of the
UM6P;
• the nature of the research activity;
• the nature and extent of an Investigator’s role in the project; and
• the identity of the external part.
5.18. If the RCOI can be managed, the Head of Department will approve or assist the investigator in developing the management plan.
5.19. If the RCOI cannot be managed, the investigator should terminate the relationship giving rise to the RCOI.
Disciplinary action
5.20. Failure to comply with this policy, including failure to disclose information required by this policy; disclosure of incomplete, erroneous, or misleading information; or failure to
comply with prescribed management plans or monitoring procedures, will be handled under UM6P disciplinary policies and procedures.
5.21. In the event an investigator fails to comply with this policy, the UM6P will decide on the appropriate sanctions. Sanctions may include, without limitation, one or more of the
following:
• removal from a specific project;
• letter of reprimand;
• special monitoring of future work;
• disciplinary actions in accordance with the labor code.
Record Retention
All disclosures, conflict management plans, and related documents are retained for a period of at least seven (7) years following the expiration of the term of the management plan. If the
conflict is connected to a sponsored program, UM6P will maintain records for at least seven (7) years following submission of the final expenditure report for the applicable project to the
sponsor of the research that gives rise to a Financial Conflict of Interest, unless any litigation, claim or negotiation, audit, or other action involving the records is commenced before expiration of the seven-year period, in which case, records will be retained until completion of the action and resolution of all issues.
SECTION 6 REVIEW AND MONITORING STATEMENT
6.1. This policy document is reviewed once every four (4) years, or more frequently when requested by the President or subsequent changes in regulations or accreditation requirements.