Conflict-of-interest policy

1. Purpose, scope and definitions

This proposed policy covers governing members, employees, researchers, students, volunteers, advisers, reviewers and others making decisions for BILSER. Relevant expectations must also be included in supplier and collaboration agreements. A disclosed interest is not, by itself, wrongdoing.

An actual conflict exists when another interest compromises an institutional duty; a potential conflict may arise in future; a perceived conflict could reasonably appear to influence judgment. Financial interests, personal relationships, competing duties and institutional incentives all fall within scope.

2. Interests requiring disclosure

• Employment, consultancies, paid advice, honoraria, travel support, gifts, funding, equity, patents, royalties and other financial benefits relevant to the decision or research.
• Close personal or family relationships, supervision, recent collaboration, professional rivalry, outside appointments and competing commitments that could affect impartiality.
• Institutional interests, including commercial partnerships, intellectual property, donor dependence or reputational incentives that could distort independent assessment.
• Related-party interests in hiring, procurement, grant allocation, access to data or facilities, authorship, peer review and misconduct proceedings. Disclose relevant interests even when no money changes hands and regardless of value.

3. When and how to disclose

• Submit a signed declaration on appointment, annually thereafter, before a relevant decision or submission, and within 30 days of a material change. Disclose immediately before participation if the matter cannot wait. Submit a nil declaration when there is nothing to report.
• For institutional declarations, describe current interests and relevant relationships during the previous 36 months, plus any older interest that remains material. This is a proposed BILSER reporting window; a funder or journal may require a different or longer period.
• State the organization or person concerned, nature of the relationship, period, financial value or range where relevant, related decision or study, and a suggested management step. Avoid unnecessary personal information about other people.
• Send the declaration to the appointed Secretary through an approved restricted channel. Until that channel exists, request one through an unconflicted published leader; do not email a completed sensitive declaration to the general mailbox. The Secretary's own declaration goes to an unconflicted Chairperson; the Chairperson's goes to an independent reviewer designated by unconflicted members.

4. Assessment and management plan

An unconflicted reviewer records the relevance, likelihood and seriousness of influence, risk to participants and institutional trust, and whether safeguards can work. The proposed target is an initial assessment within ten working days; until a decision is recorded, the individual must not take part in the affected decision. The declarant may explain or correct the information.

A written plan identifies the interest, restrictions, responsible monitor, review date and evidence of compliance. Measures may include disclosure to affected parties, independent supervision or analysis, access restrictions, removal from recruitment or procurement, divestment, reassignment, or refusal of a relationship. Decline or stop the activity where risk cannot be managed.

The conflicted person must not approve their own plan. Apply at least the relevant funder, journal, ethics-committee and contractual requirements, and resolve inconsistent obligations before proceeding. Written disclosure alone does not make an otherwise prohibited activity permissible.

5. Recusal and related-party transactions

• Declare before the agenda item, provide factual information only if requested, then leave the discussion and vote. Do not lobby the remaining decision-makers or use confidential material for private advantage.
• Record the declaration, absence, revised quorum, independent assessment, options considered and decision in the minutes. An interested person does not count toward the item's quorum. Defer if the necessary unconflicted quorum is unavailable.
• For a permitted related-party purchase or appointment, document genuine need, fair comparison, reasonable value and approval by unconflicted authorized decision-makers. Never allow an individual to approve their own pay, reimbursement or contract.
• Reject bribes, facilitation payments and benefits intended to influence decisions. Cash or cash-equivalent gifts are prohibited under this proposed policy. Log and independently assess other gifts; gifts offered during procurement, recruitment, ethics review or grant assessment must be declined.

6. Research, sponsors and publications

Disclose relevant relationships in study documents and communications as required by the ethics committee, funder and journal. Explain funding and the sponsor's role separately from individual interests. Document access to underlying data and responsibility for analysis.

Accept no agreement that lets a sponsor dictate conclusions or improperly suppress publication. Any limited pre-publication review for confidential information or intellectual-property protection must have a defined, reasonable duration and preserve lawful scientific reporting. Participant information must be understandable and include relevant disclosures approved by the ethics committee.

Related sources: ICMJE recommendations on disclosure of relationships and activities (opens in a new tab)

7. Register, privacy and monitoring

The Secretary maintains a restricted interests register with declarations, assessment, management plan, decision, review dates and completion evidence. The unconflicted Committee checks management plans at least annually and before material changes. Publish proportionate institutional disclosures and relevant transaction summaries without exposing private financial or family details.

Retain declarations and management records for seven years after the relevant relationship or activity ends under this proposed institutional schedule, unless a longer binding requirement or legal hold applies. Limit access to authorized reviewers, provide lawful correction rights and securely dispose of records when retention expires. Assess privacy and transfer obligations before sharing outside Bangladesh.

8. Non-disclosure, concerns and appeal

Report suspected undisclosed interests through the research-integrity reporting route. Protect good-faith reporters against retaliation. Assess omissions fairly, distinguishing inadvertent error from deliberate concealment, and take prompt proportionate protective action without presuming guilt.

Give the affected person the concern, relevant evidence and an opportunity to respond before a final decision. An unconflicted panel may require training, a revised plan, reassignment or proportionate disciplinary action consistent with law and contract. Correct submissions or published disclosures and notify responsible external bodies where required.

A written appeal may be submitted within 30 days for procedural unfairness, material new evidence or an undisclosed decision-maker conflict. A reviewer uninvolved in the original decision gives written reasons, with a target of 30 working days or a documented extension. External legal and regulatory remedies remain available.