Access to Medicine Foundation - Conflict of Interest Policy
1. Purpose
a. The Foundation aims to independently, impartially and reliably measure, monitor, review andpublish the performance of pharmaceutical companies with respect to their efforts to improveaccess to medicine globally, bring antimicrobial resistance under control and ensure all children
are immunised wherever they live.
b. The purpose of this Policy is to protect the credibility of the Foundation's decision-making andresearch processes and enable our stakeholders to have confidence in the organisation’sintegrity.
c. Transparency about the development and management of the criteria of the research
programmes/initiatives of the Foundation, as well as transparency about the assessment andmanagement of (actual, potential and perceived) conflicts of interest, are crucial to the credibilityof the research programmes/initiatives of the Foundation.
2. General policya. Any person exercising influence on methodologies, measurements and publications of the Accessto Medicine Foundation (“the Foundation”), including Supervisory Board members, staff,freelancers, volunteers, trainees and external contractors, shall have no material conflict between
their personal, professional or business interests and the integrity of the research
programmes/initiatives of the Foundation, in any and all actions taken by them on behalf of or for
the Foundation in their respective capacities.
b. The Foundation does not directly nor indirectly recommend the purchase or sale of equity
securities, nor does it hold such assets.
3. Definition of material conflict of interesta. Actual, potential (could develop) or perceived (could be considered likely) conflicts of interest canarise across all areas of our work. Conflicts may be of a personal, financial or political nature.
b. A material conflict of interest is an interest which, in view of all the circumstances, could
reasonably be expected to affect the independence, impartiality and reliability of the person withthe interest.
c. Material conflicts of interests of individuals related to the research programmes/initiatives of theFoundation could lead to:i. biases in measurements, monitoring or reviews;
ii. biases in the publication of measurements, monitoring or reviews;
iii. misuse of privileged and confidential knowledge.
4. Non-exhaustive list of actual, potential and perceived conflicts of interest
a. Having a direct financial interest in a company that is measured by the research
programmes/initiatives of the Foundation;b. Having direct possession, purchase or sale of equity securities in a company that is measured by
the research programmes/initiatives of the Foundation;c. Providing privileged or confidential information or advice to third parties which can be used todecide on such purchase or sale;d. Receiving financial compensation, gifts, hospitality or other favours from a company that ismeasured by the research programmes/initiatives of the Foundation or from a company that has
itself a conflict of interest; financial compensation includes direct and indirect remuneration as
well as gifts, hospitality or favours worth 50 euros or more;e. Having a close family member (e.g. spouse, parent, child or spouse of a child, brother, sister, orspouse of a brother or sister) with such interests;
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f.

Other interests that have been deemed potentially conflicting by the Supervisory Board.

5. Reporting and management of actual, potential and perceived conflicts of interest
a. Upon appointment, any person exercising influence on methodologies, measurements andpublications of the Foundation, including Supervisory Board members, staff, freelancers,volunteers, trainees and external contractors, shall disclose actual, potential and perceived
conflicts of interests to their line manager, contact person at the Foundation or the Finance Team(finance@accesstomedicinefoundation.org) through the Conflict of Interest Declaration Form
(Annex 1).
b. New conflicts of interest shall be reported through the same Conflict of Interest Declaration Form
(Annex 1) within 5 working days after they arise.
c. As soon as a declaration has been made, line management, contact persons at the Foundation or
the Finance Team must ensure that they review all declarations within five working days andreport them to the Management Team, with a recommendation of mitigating actions (if needed).
d. The Management Team shall evaluate all declarations of conflicts of interest withing five working
days and decide whether they are ‘material’ conflicts of interest and what mitigating actions isrequired (if needed).
6. Context for gifts and hospitalitya. It is widely recognised that it is important for employees, board members and contracted
employees to maintain and build effective networks in order to support the work of theFoundation, and to gain a real understanding of the views of stakeholders. However, contact withorganisations outside the Foundation can give rise to offers of gifts and hospitality.
b. While accepting gifts and hospitality in certain circumstances may further the Foundation’s
interests, this must be balanced with upholding high standards of propriety and guarding against
any reasonable suspicion of perceived or actual conflicts of interest or an undue obligation beingcreated.
7. Acceptance of gift and hospitality
a. When working on behalf of the Foundation, any person exercising influence on methodologies,measurements and publications of the Foundation, including Supervisory Board members, staff,freelancers, volunteers, trainees and external contractors, should not normally accept gifts andhospitality. The only exceptions are those which would normally be considered as isolated trivial
gifts e.g. low value items that can be used or displayed in the workplace such as office stationeryor mouse mats or inexpensive seasonal gifts such as diaries and calendars, event goodie bags,
tokens of appreciation for speaking engagement (e.g. books, stationary etc.), or food/beverages
provided to those in attendance at meetings and events.
b. Any hospitality accepted should be in the interests of the Foundation and help further its
objectives. It should not be over-frequent or over-generous. Accepting hospitality from the sameorganisation could lead to a perception that the work of the Foundation is being influenced by theobjectives of a single organisation. Any hospitality accepted should not seem lavish or
disproportionate to the nature of the relationship the person has with the provider.
c. The Foundation recognises that in some cases non-acceptance may cause embarrassment to theprovider. Gifts which cannot be refused without causing offence (for example, a picture or anornament) must be accepted “on behalf of the Foundation”, making it clear that it is not being
accepted as a personal gift. Such gifts must be kept within the Foundation and displayed in ageneral area.
d. When working on behalf of the Foundation, any person exercising influence on methodologies,
measurements and publications of the Foundation, including Supervisory Board members, staff,
freelancers, volunteers, trainees and external contractors, must declare and report all gifts andhospitality (accepted or declined) that are valued over 50 euros to their line manager, contact

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person at the Foundation or the Finance Team within 5 working days after the gift and hospitality
was offered. Reporting should include the person and/or organisation providing the gift, adescription of the gift, its estimated value and the date in which the gift was received.
e. If there is any doubt about whether or not hospitality or gifts should be accepted, the person
should seek advice and guidance from their line manager, contact person at the Foundation orFinance Team.
8. Confidentiality
a. Research outcomes are confidential until their formal time of release. Any individual within theFoundation or working for the Foundation who has advance knowledge of research
programmes/initiatives outcomes shall not disclose any part of such outcomes to third parties
before the formal time of release.
9. Review of the Policya. The Supervisory Board shall review this Policy at least once per year and apply all changes
necessary to maintain the impartiality, independence and reliability of the research
programmes/initiatives of the Foundation.
10. Corrective actions
a. Any material conflict of interest or any violation of the rules set forth in this Policy shall prompt
disciplinary and/or corrective action by the Management Team and/or Supervisory Board.
b. A charge of incompletely or inaccurately disclosed conflicts of interest shall be directed to theManagement Team or, in case of Supervisory Board members, to the Chair of the Supervisory
Board.
c. The Management Team or, in case of Supervisory Board members, the Chair of the Supervisory
Board shall take no action until it has given the person charged with the alleged conflict ofinterest the opportunity to fully represent him/herself.
d. The Management Team or, in case of Supervisory Board members, the Chair of the Supervisory
Board may appoint a disinterested person or committee to investigate the alleged conflict ofinterest.
e. The person with the alleged conflict of interest shall not take part in any vote on the nature of theinterest or any related decision.

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Annex 1- CONFLICT OF INTEREST DECLARATION FORM
To be completed and signed by any person exercising influence on methodologies, measurements andpublications of the Access to Medicine Foundation (“the Foundation”), including Supervisory Board
members, staff, freelancers, volunteers, trainees and external contractors.
[ ] I have reviewed and understood the Conflict of Interest Policy of the Access to Medicine
Foundation and agree to abide by it.
***[ ] I have no actual, potential or perceived conflict of interest as defined in the Conflict of Interest
Policy of the Access to Medicine Foundation.
OR[ ] I report the following conflicting interest(s), as defined in the Conflict of Interest Policyof the Access to Medicine Foundation.
Please describe fully, including name and nature of the interest.
1. ______________________________________________________________________________________________________________________________________
2. ______________________________________________________________________________________________________________________________________
3. ______________________________________________________________________________________________________________________________________

I hereby certify that the information provided is true and complete to the best of my knowledge,that I will adhere to the decisions on conflicts of interest adopted by the Access to Medicine
Foundation; and that I will report future changes to this information to my line manager, my contact
person at the Foundation or the Finance Team (finance@accesstomedicinefoundation.org) within 5
working days after they arise.

Name:______________________________________

Position:______________________________________

Signature: ______________________________________
City, Date: ______________________________________

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