Conflict of Interest Policy
Non-Conflict of Interest (CoI) policy and processes
The purpose of this public information appearing in the e-IRG website is to summarise the non-conflict of interest policy and processes of e-IRG.
- Rules for participation in e-IRG
According to the e-IRG bylaws national governments, Member State, Associated Countries and European Commission nominate the e-IRG delegates; up to two members, usually one from the ministry and a second from the e-Infrastructure area.
- Non-CoI policy, addressing rules of publications and participation in e-IRG bodies
e-IRG has put a Non-Conflict of Interest Policy in place and measures to eliminate and/or authorize a possible conflict of interest. These rules address the participation in e-IRG Working Groups and Task Forces, which are the source of e-IRG publications, as well as the participation in the decision-making processes of e-IRG bodies. In more detail the following items have been developed:
- Non-CoI policy (that includes ethical principles and a Declaration of No Conflict of Interest form to be signed by delegates participating in a Working Group/Task Force that is expected to publish a document
- e-IRG delegates e-Infrastructure involvement template that is filled by all e-IRG delegates/support and used to summarise the involvement of e-IRG delegates in the area of e-Infrastructures. A register of delegates involvement information (based on this template) will be maintained inside the e-IRG delegates private webspace.
- e-IRG Working Group/Task Force Terms of Reference template (that includes a Conflict of Interest section)
- A section in each publication describing the participating members and a summary of the publication process
- Rules of representation of e-IRG (talk on behalf of e-IRG)
Delegates speaking in their role as e-IRG members will inform the e-IRG plenum for upcoming opportunities to present e-IRG, e-IRG publications or other e-IRG matters. In case any delegate foresees a potential conflict of interest or other benefit, she/he will raise it to the e-IRG plenum. The e-IRG Executive Board will discuss the issue and take a decision which will be shared with the plenum, either to authorise the CoI or propose that another delegate represents e-IRG. Delegates representing e-IRG should express statements in line with e-IRG decisions and documents.
The following is a template to gather information about the involvement of e-IRG delegates. The level of information that will be published will be further discussed in the upcoming e-IRG.
e-IRG delegates e-Infrastructure involvement template
To address the Non-conflict of Interest personal information of e-IRG delegates will be collected, the following paragraphs address GDPR-related issues of this data collection.
Purpose of the document
The purpose of this template document is to facilitate the collection of e-IRG delegates involvement in e-Infrastructure initiatives, projects and activities as well as their roles in these. The analysis of such information as a whole will be used to assess the independence and neutrality of e-IRG body and enable the identification of possible Conflict of Interest (CoI) during the involvement in e-IRG activities. The collection of data will be used to provide statistical summaries for e-IRG documents and other output, and not linked to individual delegates.
All e-IRG members (delegates + support project members) are asked to list in the predefined table below their involvement in the e-Infrastructures area.
Each e-IRG delegate is responsible to keep her/his template up-to-date, and will be supported by the e-IRG secretariat. At the time of the nomination of a new delegate, the e-IRG secretariat will ask the delegate to fill in this template.
Storage and publication level
The filled-in template of each delegate will be stored in the e-IRG delegates private webspace. The collected information of an e-IRG delegate or member of the support programme will be stored until the concerned person leaves e-IRG or the the support programme and afterwards deleted.
Please fill in the following table for all the e-Infrastructure-related projects (EC or international or national) and committees, along with your employer’s name, that you are currently involved in for reasons of transparency and avoidance of Conflict of Interest.
I certify that the information above is accurate and I give consent to publish this information in the e-IRG delegates private web space.
Date: ____________________ Signature:_________________
e-Infrastructure Reflection Group Non-Conflict of Interest Policy
All e-Infrastructure Reflection Group (e-IRG) delegates, external experts and members of the e-IRG Support Programme who are taking part in an e-IRG governing or editorial activity will strive to avoid any conflict of interest between interests that result from the vision, mission, objectives or mandate of e-IRG on the one hand and their professional, personal, and business interests. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.
The purpose of this policy is to protect the integrity and independence of the e-Infrastructure Reflection Group and its decision-making processes, and to enable all stakeholders to have confidence in e-IRG’s neutrality and lack of bias, and to protect the impartiality and reputation of its members and e-IRG itself.
e-IRG, with the support of the secretariat, collects background information of each delegate through the e-IRG delegates e-Infrastructure involvement template and will store this information. Upon request this information may be disclosed to the European Commission following a decision by the e-IRG plenum or the e-IRG Executive Board mandated by the plenum.
In the course of any e-IRG governing or editorial activity, delegates will disclose any interests in a transaction or decision where there may be a conflict between e-IRG’s best interests and the delegates’ best interests or a conflict between the best interests of two organisations or undertakings that the delegate is involved in. If in doubt the potential conflict must be declared anyway and clarification sought.
If a conflict of interest exists, it is a case by case decision if the conflict will be authorised or not.
Authorising a Conflict of Interest
In case of a potential conflict of interest arising for an e-IRG delegate, an external expert or a member of the e-IRG Support Programme because of a duty of loyalty owed to another organisation or person, and the conflict is not authorised by virtue of any other provision in e-IRG’s bylaws, the un-conflicted delegates may authorise such a conflict of interest where the following conditions apply:
- The e-IRG delegates permission is sought before a benefit may be authorised that isn’t otherwise authorised in the e-IRG bylaws or Terms of Reference; or
- The e-IRG delegate, external expert, or member of the e-IRG Support Programme who has declared the conflict of interest withdraws from the e-IRG governing or editorial activity at which there is any transaction affecting that other organisation, undertaking or person.
- The e-IRG delegate, external expert, or member of the e-IRG Support Programme who has declared the conflict of interest does not vote on any such matter and is not to be counted when considering whether a quorum is present at the meeting of a governing body or editorial activity; or,
- The other e-IRG delegates who have no conflict of interest in this matter consider it is in the interests of e-IRG to authorise the conflict of interest in the circumstances applying.
- In all cases, any such disclosure and the subsequent actions taken will be noted in the minutes of the relevant meeting or committee, or in the colophon of the e-IRG document.
For all other potential conflicts of interest the advice of the e-IRG Chair and Executive Board will be sought and the advice recorded in the minutes. All steps taken to follow the advice will be recorded.
Declaration of No Conflict of Interest
A Declaration of No Conflict of Interest is a) to be signed by each member of an e-IRG governing body or b) mandatory part of each Terms of Reference document, which is obligatory for every e-IRG document and every member of an e-IRG working group signs this declaration at the initial meeting of an e-IRG Working Group or Task Force or any other editorial composition.
I, the undersigned, in respect of my assigned involvement in the …(insert name of governing body or title of the e-IRG Working Group/Task Force)… (collectively referred to below as ‘Activity’) confirm that I:
Place and date: …(insert place, DD-MM-YYYY)…
The e-Infrastructure Reflection Group Conflict of Interest Policy is meant to supplement good judgement, and e-IRG delegates, external experts and members of the e-IRG Support Programme should respect its spirit as well as its wording.
Terms of Reference for documents
Responsibility and Ownership
All participants in this Working Group/Task Force commit their time to achieve the objectives set. This involves more than attendance at meetings. All delegates are expected to actively participate and share the workload.
Communication work plan
Duration and Deadlines
The Working Group/Task Force Chair will report the status of this activity at the e-IRG Delegates Meeting, which will be held under the … (country) … Presidency of the Council of the European Union in ... (date) … and report about the outcome in the delegates meeting in … (date) ... under the … (country) … Presidency of the Council of the European Union.
Conflict of Interest
This list will be added as an annex to the final document.
e-IRGSP7 has received funding from the European Union’s Horizon Programme call HORIZON-INFRA-2021-DEV-01-05, Grant Agreement number 101057802.