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Independence is a critical issue for Therapeutic Guidelines Limited (TGL). Its reputation is staked on its publications and the independence of the therapeutic information that has been developed by its expert groups through interpretation of the literature and distillation of expert opinion.
Key factors for this independence are:
- TGL being wholly independent of any form of government or commercial sponsorship including the pharmaceutical industry, and
- TGL enforcing a strict policy on conflict of interest for Directors and members of its expert groups.
The pharmaceutical industry and government both rely heavily on bodies outside their own spheres, such as universities and hospitals, for product development and regulation. In this context, given their experience and expertise, it is likely that Directors and members of expert groups have, or have had, some association with the pharmaceutical industry and/or government committees. Members of the Company, Directors and staff of TGL
Members of the Company, Directors and staff of TGL are appointed on the basis of their overall expertise and interest in the core activities of TGL, especially therapeutics and the delivery of information.
It is the individual responsibility of all Members of the Company, Directors and staff of TGL to identify and disclose:
- any real or potential for conflict of interest they or their associates might have in undertaking their duties for TGL, and
- any relationship they might have with TGL.
Members of the Company, Directors and staff of TGL are required to provide to the Chairman of the Board, a written interest statement, on an annual basis.
In addition, if a Director believes that there is an identified or potential conflict of interest with regard to an agenda item for a Board meeting, a statement must be provided prior to the commencement of that meeting. If, in the opinion of the Chairman, a conflict imperils the independence of the decision-making process, the Chairman may request that person to absent him/herself from the meeting. If, in the opinion of any Director, a conflict imperils the independence of the Chairman, that Director may request the Chairman to absent him/herself from the meeting. Expert group members
Members of the expert groups are appointed on the basis of their expertise in therapeutics, and their integrity in providing independent advice. It is the individual responsibility of all members of expert groups to identify and disclose any real or potential for conflict of interest in the development of therapeutic information.
Prior to the initial meeting of the group, expert group members are required to provide to the Chief Executive Officer of TGL, written interest statements which will be tabled at the initial meeting of the group. In addition, if a member believes there is an identified or potential conflict of interest with regard to an agenda item for a subsequent meeting, this must be declared to the expert group.
Following a declaration of a potential for conflict of interest, a member may be asked by the Chairman to absent him/herself from the meeting while the expert group deliberates and makes its determination. The member’s exclusion shall be recorded in the minutes.
It is the responsibility of each expert group to deliberate on any real or potential conflict of interest declared by a member of that expert group (including the Chairman), to determine whether a conflict of interest exists and the member’s subsequent involvement.
Alternatively, concern about conflict of interest within an expert group may be referred to the Board, not necessarily through the Chairman of the expert group. Referral may be effected through a confidential communication to the Chief Executive Officer.
If an expert group or the Board of TGL considers a possible conflict and determines that a member of an expert group does not have a conflict of interest with an agenda item, the member’s name and the determination of the group shall be recorded in the minutes. Interest statements
Interest statements must comprise a declaration of any interests that may be capable of influencing advice or decisions relating to the operation or activities of TGL.
Interests may be academic, professional, personal or financial (including equity interest, consultancies, or research support). Sources of research funding and membership of advisory boards of commercial companies, especially in the past five (5) years, should be declared if it is relevant to any issue being considered. Associations may be with either government or with a company that stands to gain from the use of any product (or its competitor) recommended in the guidelines.
Interest statements are held in confidence at TGL.
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