Ludwig Institute for Cancer Research Ltd
CONFIDENTIAL DISCLOSURE POLICY FOR STAFF MEMBERS
Effective Date: August 24, 2012
Last updated: March 19, 2013
Confidential Disclosure Policy for Staff Members
Confidential Disclosure Policy for Staff Members
The Ludwig Institute for Cancer Research Ltd (the Institute) and the LICR Fund (Fund) maintain the highest standards of honesty, integrity and impartiality. In the course of pursuing the mission of the Institute and the Fund, staff may be involved in extramural activities, hold appointments from and have significant financial interests in, other organizations. Disclosure of these activities, appointments, and interests by Institute and Fund staff allows the Institute to meet the expectation of these high standards and proactively manage potential conflicts disclosed.
1. DESCRIPTION
a. Extramural activities
- i. Examples of extramural activities include but are not limited to: appointments to and activities for professional associations and government agencies, and professional activities with outside academic or not-for-profit organizations such as teaching or lecturing responsibilities, membership on editorial or other boards or academic or government committees.
b. Outside Appointments
- i. Examples of outside appointments (appointments outside of the Institute or Fund) include but are not limited to owner, investor, member of the board or a committee, officer, director, trustee, partner, investigator, employee, or consultant. Outside appointments may be compensated or non-compensated.
c. Significant Financial Interests (SFI)
SFI exists when
- i. A staff member of the Institute or Fund or their spouse or dependent children, has an outside appointment, as defined in Section 1.b, with or holds a financial interest in, a publically or non-publically traded entity that, as far as the staff member is aware, supplies to or receives from the Institute or Fund, funds, goods, or services or proposes to do so, or collaborates with the Institute or Fund and,
ii. The value, aggregated for a staff member, their spouse, and dependent children, of any remuneration, e.g., honoraria, consulting fees, paid authorship, etc., received from any single publically traded entity, as described in 1.c.i above, in the twelve months preceding disclosure plus the value, aggregated, of any equity interest in any entity as of the date of disclosure is greater than $5,000 or,
iii. The value, aggregated for a staff member, their spouse, and dependent children, of any remuneration received from any single non-publically traded entity, as described in 1.c.i above, in the twelve months preceding disclosure is greater than $5,000, or a staff member, their spouse, or dependent children hold any equity interest (e.g., stock, stock options, or other ownership interest) or,
iv. There is receipt of income related to intellectual property rights from an entity other than the Institute or Fund.
d. Reimbursed or Sponsored Travel
- i. Reimbursed travel is defined as travel whereby travel expenses are reimbursed directly to the staff member for travel requested or required by any entity outside the Institute for the purpose of utilizing the professional expertise of a staff member for which they hold their Institute or Fund appointment. Reimbursement of travel for extramural activities described in Section 1.a. above, is not included in this definition for disclosure purposes.
ii. Sponsored travel is defined as travel whereby travel expenses for a staff member are paid directly for travel requested or required by any entity outside the Institute for the purpose of utilizing the professional expertise of a staff member for which they hold their Institute or Fund appointment. Travel expenses for a staff member involved in extramural activities described in Section 1.a. above, paid directly are not considered sponsored travel for disclosure purposes.
2. DISCLOSURE
a. Every Institute and Fund staff member except for undergraduate students (the “relevant staff member”) must disclose all extramural activities, all outside appointments, SFIs and reimbursed or sponsored travel:
- i. Prior to the commencement of employment with the Institute
ii. Annually as of April 1 of each year thereafter
b. Every Institute and Fund relevant staff member must disclose, when known, any new outside appointment, SFI, or reimbursed or sponsored travel.
c. A Confidential Disclosure Form (CDF) will be completed by each Institute and Fund relevant staff member at least annually.
- i. Each year, the Secretary to the Board of Directors, on behalf of the respective Board of Directors acting through its Audit Committee, shall send a CDF to each relevant staff member of the Institute and the Fund via their Administrator.
ii. The CDF shall be completed by each relevant staff member of the Institute and the Fund and returned to the Secretary to the Board of Directors via their Administrator by May 1 of the respective year.
iii. It shall be the continuing duty of each relevant staff member to advise the Secretary promptly upon the occurrence of any new outside appointment, SFI, or reimbursed or sponsored travel which was not but should have been described in the most recent CDF had it been known at the time the form was completed.
iv. Failure to disclose extramural activities, outside appointments, SFIs and reimbursed or sponsored travel constitutes grounds for disciplinary action.
d. Copies of the completed CDFs for Officers, Directors, and Member-track scientists shall be provided to the Chairman of the Audit Committee by the Secretary.
e. Except as required by law or United States Public Health Service policy, disclosures are confidential.
