EAS Policy on Management of Conflict of Interest
(updated April 2024)
The European Atherosclerosis Society’s (the EAS) goal is to provide a framework for concerted scientific and clinical discussion of new developments in basic research, diagnosis and therapy of atherosclerosis, through a programme of educational and publication activities arranged for and by its members.
- Publication of Guidelines and Consensus Position Papers, and Journals Atherosclerosis and Atherosclerosis Plus
- Organizing an Annual Congress and Advanced Course programmes
- Producing online educational content on EAS Academy learning platform
The EAS is committed to transparency and managing actual and perceived conflicts of interest that may arise in the organisation of these programmes, in order to preserve the integrity of the activities in which the EAS and its members are engaged.
EAS takes seriously its commitment to provide unbiased publication and educational programmes through transparency and proper management of conflicts of interest. In practice this means that:
- Potential Executive Committee candidates must declare any conflicts of interest before being nominated for election, agreeing to resolve such conflicts and comply with all relevant aspects of this EAS Policy on Management of Conflict of Interest is a prerequisite for inclusion on the election slate.
- All EAS committees must be aware of and have discussed this Policy on Management of Conflict of Interest.
- A meeting speaker is provided with a reminder about this EAS Policy on Management of Conflict of Interest prior to his/her presentation and is asked to disclose potential conflicts at the beginning of the presentation.
EAS regulations on handling conflict of interest, transparency and ethical integrity
GENERAL PRINCIPLES
1. Defining a conflict of interest:
A conflict of interest exists when an EAS Volunteer (as defined below) has material interests that could, or could be perceived to, influence his/her decisions, actions or presentations in an inappropriate or biased manner. These interests include employment, consultancy, equity, research funding, honoraria, patents and royalties that derive therefrom, speaking commitments, positions on advisory committees or board of directors, expert testimony and financial support from a person (such as a company) with commercial interests. Subsidy of travel expenses and/or accommodation/hospitality by a person for/during an EAS activity is also considered a conflict of interest.
Conflicts of commercial interest may involve either an agent, pharmaceutical or medical device concerning the subject in question or an agent pharmaceutical or medical device that might be in competition with the subject in question.
2. EAS educational and publishing activities must be without bias:
Persons contributing to the EAS educational and publication programmes must do so without bias resulting from any of the material interests mentioned above.
3. To whom does this policy apply:
Members of the Executive Committee, Election Committee and other committees; members nominated as Officers or members to the Executive Committee or other committees; participants in panels and taskforces for guidelines and consensus publications; presenters and chairs in Congresses and both live and online courses; and employees of the EAS (all defined as “EAS Volunteer”).
4. Disclosures of potential conflicts of interest:
It is the responsibility of the EAS Volunteer to disclose in full all actual and/or potential conflicts of interest so that the Members or any third party may be able to evaluate the relevance of the potential conflict of interest. Such disclosure shall be made on a disclosure form as provided by the Executive Committee from time to time, and according to the instructions set out therein (the “Disclosure Form”). The Disclosure Form shall be made available on the EAS website.
5. Transparency and professional integrity are required:
There are varying degrees of conflicting interests. Relationships with commercial partners does not necessarily mean an individual is precluded from a role within the EAS, as long as the relationships are declared and considered not to be inappropriate by the Executive Committee and/or the Election Committee. This applies equally to all aspects of clinical practice and basic science research.
6. No promotion – EAS integrity and industry support:
EAS does not promote pharmaceuticals, nutraceuticals, medical devices or other products related to the area of interest or objectives of the EAS. Revenues generated by industry sponsorship and exhibition at Congresses or advertisements in the EAS journal shall be used solely to support the EAS independent educational programmes.
7. Industry-supported activities: publications, congresses, live & online courses.
EAS follow the guidelines for accreditation set for Continued Medical Education (CME):
- Commercial support and interests, where applicable, is acknowledged and disclosed.
- There is no involvement by any representative of the supporting company in the development of the activity, including but not limited to influencing any parts of the scientific, academic or social agenda of the activities.
- Where applicable, attendees are invited to report on their perceptions of any possible bias.
8. When writing Guidelines & Consensus publications:
The EAS participates in the development of evidence-based clinical practice guidelines. Academic independence and integrity are especially important in the development of clinical guidelines, and so particularly rigorous standards are required. Special policies intended to prevent bias from conflicts of interest apply to any EAS Volunteer participating in guideline development. These are given in Appendix 1.
In cases where Consensus position papers are funded by educational grants from pharmaceutical or medical device companies paid to the EAS, these grants are unrestricted, and the initiatives must have multiple grant providers. The grant providers have no influence on the content, and no access to, nor knowledge of the content prior to publication. Consensus panel members must sign a confirmation of confidentiality preventing disclosure of any information concerning the paper prior to its publication.
9. Educational Programme creation – free from commercial influence
- Each individual in a position to determine the content of an educational activity must disclose all relevant financial relationships that involve the receipt of wages, compensation, benefits or other remuneration for their services as an employee, consultant or other position that involves any commercial interest and follow this EAS Policy on Management of Conflict of Interest.
- The terms, conditions and purposes of any commercial support of a CME programme are documented in a written letter of agreement between EAS and the commercial supporter. Such agreement must always state that EAS makes all decisions regarding the scientific, academic and social content of the programme, selection of speakers, and disbursement of commercial support.
- Acknowledgment of commercial support is provided on the EAS website, in the printed meeting materials, and on any signage or other visually provided material on-site.
- Product promotion (including pharmaceutical products and medical devices) and product-specific advertisement of any type are prohibited in or during CME activities.
10. Monitoring/Administration/Disclosure of Conflicts:
- Conflict of interest disclosures for EAS Volunteers are updated annually and are available for EAS Members (as defined in the Constitution) on the EAS website.
- For publications and CME activities, relevant disclosure information is provided to the audience in conjunction with each activity. The disclosure identifies those in receipt of salary, compensation, benefits or other remuneration for their services as an employee or consultant, as well as those who report no financial relationships.
- For EAS Congress & other CME meetings, each speaker is required to disclose information on a slide shown before the presentation.
- In EAS publications, author disclosures are provided in a prominent location.
We follow the below procedure to ensure compliance with the disclosure policy and address any issues as they arise.- In preparation of a EAS Congress, EAS staff members shall request and receive a disclosure slide for each presentation made at the Congress. This disclosure slide shall provide the same detail as referenced in the Disclosure Form on the EAS website.
- In the case that an EAS Volunteer does not comply with this Policy on Managing Conflict of Interest or does not complete their Disclosure Form annually (“failure to disclose”), they will be given written notice by the EAS to rectify the matter and if not done in a reasonable time they will be required to step down from their position. Until the disclosure is made, they will not subsequently contribute to any EAS activity, pending EAS Executive Committee decision on appropriate action, determined on a case-by-case basis. Such action may range from a written warning to the individual about adherence to the EAS Policy on the Management of Conflict of Interest to prohibition from participation in future EAS events.
- EAS has the right to review and address any questions about actual or potential conflicts of interest. Individuals who fail to comply with this EAS Policy on the Management of Conflict of Interest will be subject to disciplinary action. Such action may range from a written notice by the EAS to rectify the matter to exclusion from EAS.
- If circumstances change during a EAS Volunteers term of office in a way that a conflict of interest arises, the member will be required to rectify the circumstance according to the Executive Committees instructions or step down from their EAS position for the remainder of their term.
11. Evaluation of potential Conflict of Interest Situations
Below are some examples on situations that might indicate that a conflict of interest exists. The list below is not exhaustive. An evaluation of the conditions in each individual case must be performed. The aim of the evaluation is that the individual should be able to act objectively and unbiased without jeopardizing the interests or reputation of the EAS. The evaluation can depend on whether it is an ongoing or a completed assignment. In some cases, the competing interest may only relate to one specific task or activity and not the entire assignment or position of an individual EAS Volunteer. Relevant for the evaluation is if the EAS Volunteer has an interest in or is reimbursed by a company, organisation, or society within the industry that has a competing interest with EAS, or if such company, organisation or society may have interests in influencing the EAS to any extent.
Guidelines to the list below can be found in Appendix 2.
The evaluation process is initiated by the EAS office, requesting disclosure forms for potential conflicts of interest to be completed and provided i.) prior to filing with the election committee, and ii.) updating such disclosure forms on a regular basis during the period of office with the EAS.
The purpose of the disclosure forms is to provide transparency to the EAS members and to allow the Election Committee or Executive Committee (as the case may be) to perform a fair assessment of the activities potentially carried out by the candidate or officer.
It should be specifically noted that the purpose of the disclosure form is not to prevent officers from performing certain activities. However, there may be candidates or volunteers whose potential conflict of interests may not allow they to perform roles and responsibilities with the best interest of the EAS in mind.
Examples of certain activities that are generally judged as more likely to create a conflict of interest with the EAS, is leadership positions or paid position within the industry, or holding a senior position (such as board member, executive or similar) of another international organisation, society or similar, that has the same or a similar purpose as the EAS.
Matters that may (but don’t automatically) constitute a conflict of interest are where an EAS Volunteer;
- Holds a leadership position or position as paid employee or consultant with a company that produces, markets or distributes products related to atherosclerosis treatment or research or other similar business area that relates to another medical field,
- Holds positions i.) within another organisation or society with similar or competing objectives/purposes as EAS, or ii.) where such organization or society competes for the same membership constituency, funding, guideline drafting or advisory positions or participation in research activities, or iii.) where such organisation may receive information from the EAS Volunteer that is privileged and confidential for EAS or any other information that could be detriment to EAS if so disclosed, or iv.) where such engagement may have an adverse reputational effect on the EAS.
- Owns or holds a controlling interest in the form of equity (including but not limited to stock, stock options, royalties etc.) in a company referenced under (a), whereby controlling interest means having power to influence the business operations or business decisions of such a company, or where the individual in any other why acts as a representative of such company or can be deemed to be a significant contributor to the business activities of such a company.
- Holds positions as a board of director or is on the advisory board of a company referenced under (a).
- Holds shares or equity in a public or private company referenced under (a)
- Receives any kind of remuneration, benefit, economic support, funding or grant from an entity with a commercial interest related to the field of atherosclerosis, etc.
- Participates in training or educational activities or speaks on behalf of a company or an organisation referenced under (a) or (b), or acts as a consultant or advisor or provides services for remuneration for any such organisation.
- Participates in research projects or other specific projects within the field of atherosclerosis or any other field of medical science that may overlap with the objectives of EAS.
- Acts as adviser towards institutional entities or other organisations regarding grants for research activities in the field of atherosclerosis.
- Owns or controls patents related to products that may have applications within the field of atherosclerosis.
- Has participated in research financed or facilitated by a company referenced under (a), drafted or collaborated in publications in medical journals or similar where other collaborators were influenced or provided by a company referenced under (a), or received payment to speak at meetings within the field that were arranged or sponsored by such a company;
- has participated in clinical trials arranged or supported by a company referenced under (a),
- has received in-kind benefits, travel, accommodation or gifts from a company referenced under (a);
- Has members of family to which any of the above would apply; or
- is subject to other circumstances that could serve to question a misdirected bias or loyalty towards EAS.
12. Questions
Questions and comments regarding the EAS conflict of interest principles and policy on declaration of interests can be directed to the administration office [email protected].
Appendix 1 –Clinical Practice Guidelines
- Academic independence and integrity is especially important in the development of clinical practice guidelines. For the above reason, particularly rigorous standards are required.
- No employee of a company that develops, markets or distributes pharmaceuticals or medical devices or other technology related to the field of atherosclerosis may be a member of a Guidelines committee.
- Any form of direct company support (or from any other person with a commercial interest in the guideline) for the development of a guideline is not permitted.
- All members of the Clinical Practice Guidelines committee and all members of individual Guidelines Task Forces must complete a full disclosure of interests by use of the Disclosure Form. In each separate Task Force of the Clinical Practice Guidelines Committee, these disclosures are shared between the members of the Task Force. Disclosures of interest of Task Force members are mentioned in the publication of the Guidelines and put on the website of EAS.
- Any of the following characteristics disqualifies an individual from serving on a Guidelines committee: part-time employment or salary from a company that has business interests in the field of atherosclerosis, significant ownership of shares or stock in such companies, or ownership or rights to a patent which potentially generates revenues or receipt of royalties for intellectual property related to the topic of the guidelines.
- Receipt of consultancy fees or fees for lecturing would not automatically disqualify an individual from being a member of a committee but must be fully disclosed.
- The members of a Guidelines Task Force are permitted to have related interests (such as participation in steering committees of clinical trials), but these must be fully disclosed in the Disclosure Form.
- Similar regulations as set out above apply to the members of any expert writing committee or scientific task force, appointed by any constituent body of the EAS. Disclosure of interests in the Disclosure Form is mandatory.
- Other individuals and those with interests which disqualify them from membership of a Guidelines committee may be invited to give advice because of their academic expertise.
Appendix 2 –
Comments and Guidelines to evaluation of conflict of interest situations
When determining if a conflict of interest is at hand the following shall be considered. Relevant for the evaluation is for example first and foremost whether a company, organization, or society within the industry may have or be perceived to having a conflicting interest with EAS.
- Definition of competing organisation – Although a clear definition of what a competing organisation can be, some general guidelines as to what can be construed to be a competing organisation or society is any organisation that i.) is active in the field of Atherosclerosis, and/or ii.) acts on an international level, and/or iii.) may have interest in similar forms of financing or funding, or apply for funding, grants or sponsorships from the same sources as the EAS, and/or iv.) rely on the same business models or form proposals on similar business models in a capacity as advisor to the industry, and/or v.) may have a considerable interest in the know-how of EAS, and/or vi.) have a detrimental reputational effect on the EAS.
- The individual EAS Volunteers potential influence over a company or organisation– The stronger the influence of the EAS Volunteer, the more likely the involvement may be considered to be a conflict of interest or have the potential of creating one further on.
- Nature of the involvement in a company or organisation: If the nature of the involvement would be construed to the public as a conflict of interest or being able to result in misguided loyalty, the involvement would typically be considered as a conflict of interest or have the potential to give rise to such later on.
- Duration of the involvement – If the duration of an EAS Volunteers engagement with a company or organisation within the same field as EAS is long, or historically has been ongoing for a long period of time, the risk of the involvement giving rise to a conflict of interest could be deemed to be increased.
- The extent/degree of the involvement – The extent of the EAS Volunteers involvement in a specific company or organisation will affect the assessment of whether a conflict of interest is at hand or may occur later on. If the person has a significant involvement in the form of a position as board of director of a competing company, there is typically a higher risk that a conflict of interest exists or may occur. On the other hand, if the engagement is insignificant or minor, e..g. if the EAS Volunteer has limited involvement in the business activities of a company,, a conflict of interest may not be at hand
- Ongoing or completed engagement – An ongoing engagement or engagement that might occur in the future usually indicates a risk of a conflict of interest occurring. If the engagement is not ongoing, the length of the period since the engagement ended may affect whether it should be considered as a conflict of interest or not. If the engagement occurred more than three years ago, the risk of conflict of interest has typically faded out/been neutralized. However, in some situations the neutralization period must be considered longer than three years, e.g. if the extent of the engagement was substantial (e.g. a continued period of spokesmanship for a pharmaceutical device related to the field of atherosclerosis).
- Remuneration – When evaluating a conflict of interest, all types of remuneration are of importance, such as but not limited to salary, grants, sponsorship, gifts, fundings, etc. The size or value of the remuneration and if the remuneration is based on a certain outcome or result, shall also be considered. In some situations, a payment or gratuity may not have been given to the EAS Volunteer individually, but to a project the EAS Volunteer participated in. This should be taken into account when performing the evaluation.
- Economic involvement and interest – An EAS Volunteers economic interests, close collaborations and engagements in companies, projects, business, establishments, institutions etc. within the file of activities of EAS shall be considered in assessing the actual or potential conflict of interest .
- Family ties and other relations to third parties – Family members or other closer relationships to persons involved in competing organisations or persons with commercial interests in the field of atherosclerosis should be carefully considered.
- Legal proceedings against EAS – If the EAS Volunteer has been or is involved in legal proceedings or any other type of claim with EAS, EAS’s affiliates, partners, or representatives shall typically be considered as a conflict of interest.