Official documents   Policy on Integrity and Conflicts of Interest in Research Version française

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0    Identification

Title: Policy on Integrity and Conflicts of Interest in Research

Person in charge: Dean of Research and Innovation

Approvals:

• Recommended by the Assemblée de direction on June 9, 2009 (ADD-500-351)
• Adopted by the Board of Directors on November 5, 2009 (CAD-1011-5242)

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P    Preamble

Polytechnique Montréal is known for the intensity of its research work, which classes it among the best engineering schools and faculties in Canada. In keeping with its vision, which consists of being a training institution for world-class engineers and researchers, recognized for its active role in technological, economic and social development, the institution’s research mission is to carry out pertinent, high-level research as the basis for high-quality training at the master’s and doctorate level that takes into consideration the needs of the industrial milieu and society.

Polytechnique Montréal advocates a climate of openness and respect in order to foster learning and the responsible exercise of thought, free expression and critical judgement. In return, we expect our researchers to act with integrity and to devote their skills to accomplishing this mission. These conditions are indispensable to Polytechnique Montréal’s specific contribution to the wellbeing of society.

In the past, research was mainly an individual activity, but today it encompasses the characteristics of a complex system requiring ever more time, human resources and costly scientific equipment. Competition in research, which often has a stimulating effect on creativity, can turn into competition between researchers to gain the recognition of their peers and the necessary funds to pursue their work and remain competitive.

While recognizing that researchers are generally known for their high level of intellectual integrity, the universities and organizations that finance research are aware that researchers may be placed in delicate situations now more than ever before.

This policy is being adopted following Polytechnique Montréal’s adherence with the Memorandum of Understanding on the Roles and Responsibilities in the Management of Federal Grants and Awards, by which we have committed to respecting the most rigorous standards of research integrity and conflict of interest.

With this perspective in mind, Polytechnique Montréal has developed the present Policy, which sets out the principles to which the school adheres and the rules it expects the community to follow in terms of research integrity and conflict of interest.1 The Policy also presents the responsibilities and duties of researchers and all other people working, directly or otherwise, to carry out or manage research activities. The rules encompass consultation and the disclosure of conflicts of interest, as well as an investigation procedure for allegations of misconduct.

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1    Person in charge

The Dean of Research and Innovation is responsible for the application of this Policy.

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2    Objectives

This Policy aims to:

• Describe Polytechnique’s expectations in regard to research integrity;
• Situate integrity as one of the fundamental elements of research and research training activities in order to prevent conflicts of interest and ensure that scientific integrity is respected in all forms of research, whether free or contractual, funded or non-funded;
• Identify the general principles that underpin the Policy and its field of application, and inform the Polytechnique community of those principles;
• Frame research-related activities with standards that follow these principles;
• Set out the respective responsibilities of all university partners involved in research activities with regard to the application of this Policy;
• Educate and raise awareness within the Polytechnique community with regard to the importance of respecting these principles and their related standards;
• Create a mechanism for managing conflicts of interest;
• Create an equitable and effective mechanism for processing allegations of failure to respect the principles and standards set out in this Policy.

The above objectives aim both to preserve the general public’s trust in Polytechnique and to meet the expectations of society and of Québec, Canadian and international granting agencies.

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3    Legal framework

While the list below is not exhaustive, the following policies, directives, procedures and standards may also apply:

• the Probity Policy;
• the Règlement sur les conflits d'intérêts des membres du personnel (regulation on conflicts of interest among staff);
• the Polytechnique Montréal Declaration of Student Rights and Responsibilities;
• the Politique sur l'administration des fonds de recherche (policy on the administration of research funds);
• the Politique sur les relations avec les entreprises dérivées (policy on relations with related businesses);
• the Policy on Technological Intellectual Property;
• the Copyright Policy;
• the Policy on the Ethical Conduct of Research Involving Human Subjects;
• the Procedure for the Certification of Research Projects Involving Biohazards;
• the Procedure for the Ethical Certification of Research Projects Involving Animals;
• the Certification Procedure for Research Projects Involving (or Potentially Involving) IT Risks.

The policies and rules of granting agencies, both federal (NSERC, SSHRC, CIHR, CFI, etc.) and provincial (FQRNT, FQRSC, FRSQ, etc.), may also apply.

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4    Definitions

4.1 Research

The term “research” includes all activities related to scientific discovery, creation or development that require a rigorous and systematic process, that aim to increase knowledge, and that can be carried out in the context of training or knowledge transfer.

Research activities generally include the development of a research question, the establishment of a protocol or research process, and the dissemination of results. It also includes other elements such as funding applications to external organizations, the signing of contracts, and participation in various evaluation processes.

A research activity may be financed by means of a grant, a contract or a sponsorship allotted to a researcher-professor by one or more external organizations (ex.: granting agencies, businesses, foundations, individuals, etc.) or by Polytechnique Montréal itself. The research activity may also not benefit from any specific funding.

4.2 Integrity

Research integrity is based on the process’s scientific rigour and on the intellectual honesty of researchers; on the respect of the standards, laws and regulations applicable for a given project; on the rigorous management of the data gathered and the funds allotted for that project; as well as on respect for the rights of all the people associated with the project.
4.3 Fraud

The term “fraud” refers to a set of behaviours whose essential nature is one of voluntarily falsifying the type or accuracy of certain information or data relative to research activities. Among other things, fraud includes fabrication and falsification.

The term “fabrication” refers to the invention of data or information.

The term “falsification” refers to the modification of data or results with the intention of introducing a bias.

Involuntary errors and divergences in terms of methods, theories, paradigms or the interpretation or certain results are not considered to be fraud.

4.4 Misconduct

Misconduct occurs when a researcher does not respect the laws, policies, directives and specific regulations (federal, provincial, institutional or other) that govern certain components of his or her research activities.

Scams and deception, processes by which one voluntarily misleads research participants with regard to the objectives or nature of a project, are examples of misconduct.

4.5 Plagiarism

The term “plagiarism” refers to the usurping or violation of intellectual property rights (data, writings or inventions) of another person, particularly with a view to representing oneself as the author in whole or in part of the work carried out.

4.6 Conflict of interest

The term “conflict of interest” refers to any situation that may place a person to whom this Policy applies in a real, apparent or potential conflict between his or her personal, professional or financial interests, including those of his or her immediate family, and the obligations and responsibilities he or she holds toward Polytechnique or toward his or her research partners.

The term “immediate family” designates spouses, children, brothers and sisters, fathers and mothers, fathers- and mothers-in-law, brothers- and sisters-in-law, sons- and daughters-in-law, and any other person living under the same roof as the person to whom this Policy applies.

The concept of “conflict of interest” covers a broad range of situations in which the decisions and actions of a given person may be influenced by the existence of multiple, contradictory influences. Several examples are described in Appendix 1 to this Policy.

4.7 Granting agencies

The term “granting agency” designates organizations that distribute research funds principally on the basis of peer-evaluated competitions. This includes, among others:

• provincial organizations such as the Fonds de recherche du Québec - Nature et technologies (FRQ-NT), the Fonds de recherche du Québec - Santé (FRQ-S) and the Fonds de recherche du Québec - Société et culture (FRQ-SC);
• federal organizations such as the Natural Sciences and Engineering Research Council of Canada (NSERC), the Canadian Institutes of Health Research (CIHR), the Social Science and Humanities Research Council of Canada (SSHRC), the Canada Foundation for Innovation (CFI) and the Canada Research Chairs (CRC);
• international organizations such as the National Institutes of Health (NIH) or the National Science Foundation (NSF).

4.8 Researcher

The term “researcher” designates all individuals who, regularly or occasionally, carry out research, creation, development or research training activities, including professors employed by Polytechnique, instructors, guest professors, researchers (including guest researchers), salaried research staff, post-doctoral interns and students.

4.9 Collaborator

The term “collaborator” refers to any other person involved, closely or distantly, in the carrying out or management of research, creation or development activities.

4.10 Research supervisor

The term “research supervisor” designates any person who supervises or co-supervises a research project carried out by a student with a view to obtaining a university diploma.

4.11 Administrator and support staff

The term “administrator and support staff” refers to any person who, as part of their functions, is involved in the general administration of research at Polytechnique.

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5    Scope of application

5.1    Activities targeted

This Policy applies to all research and research training activities carried out by the people targeted, regardless of the funding sources and the location where the research takes place. These activities include, among others, research development, production, dissemination, evaluation, valorisation, management, support and training.

5.2    People targeted

This Policy applies to all researchers, collaborators, research supervisors, administrators and support staff at Polytechnique Montréal. These people are obliged to read this Policy and follow it in its entirety.

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6    Integrity in conducting research activities

Society expects researchers to demonstrate integrity. Researchers have an obligation both to be competent and to act in good faith, with the understanding that the research process may give rise to errors committed in good faith, to contradictory data, or to valid differences between experiment protocols or in the interpretation of information.

6.1    Principles

Research integrity rests, among others, on the following principles:

6.1.1 Principle of the advancement of knowledge

Research activities have the primary goal of advancing and disseminating knowledge, and fall under Polytechnique Montréal’s training and knowledge development mission.

6.1.2 Principle of equity

The contribution of each partner involved in a research process must be recognized in a fair and equitable manner.

6.1.3 Principle of probity

Every step of a research process, from the initial design until the dissemination of results, including the management of research funds, must be characterized by intellectual rigour and honesty.

6.1.4 Principle of transparency

The information associated with research-related activities must be accessible in such a way as to allow for consultation and verification. This access right is, however, limited by the respect for confidentiality, as well as by the respect for the authorship of results or productions and their related patents and copyrights.

6.1.5 Principle of competency

The research-related activities that the targeted people are called upon to carry out or to evaluate must normally be closely related to their field of expertise.

6.1.6 Principle of independence

Research-related activities must not have any financial, professional or personal incidence likely to compromise the independence and objectivity of the judgements and decisions that must be made by the targeted people.

6.2    Responsibilities

This Policy involves a large number of partners, who all share responsibilities in relation to it, in varying degrees. These responsibilities are described below.

6.2.1 Responsibilities of Polytechnique Montréal

Polytechnique plays a prominent role in maintaining the highest standards of research integrity and research training. As a university institution, it is responsible for the integrity of the research under its responsibility. As an organization, it is accountable to its partners for the use of the funds they allocate to university research. In order to meet their requirements, Polytechnique Montréal has put into place measures aiming to:

• disseminate and promote this Policy;
• raise awareness among the people targeted by this Policy regarding the importance of respecting the fundamental values and principles of research integrity;
• guide and advise the people targeted by this Policy regarding questions of ethics and conflicts of interest;
• investigate allegations of misconduct and, if necessary, take appropriate action in order to protect the rights and reputations of all individuals concerned;
• communicate with the concerned parties regarding the conclusions reached and measures taken.

6.2.2 Responsibilities of the people targeted by this Policy

All people targeted by this Policy must read it and respect it fully. All people targeted by this Policy are also required to respect all the other research-related policies, procedures and institutional directives, including the Probity Policy, the Policy on the Ethical Conduct of Research Projects Involving Human Subjects, the Procedure for the Ethical Certification of Research Projects Involving Animals and the Procedure for the Certification of Research Projects Involving Biohazards.

In addition, within their research-related activities, the researchers, and as appropriate the research collaborators and research supervisor, must respect the following principles and rules.

Polytechnique Montréal also expects that the principles and standards set out in this Policy will be respected by researchers, research collaborators and research co-supervisors not employed by Polytechnique Montréal but nevertheless involved in its research activities.

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7    Integrity standards

The integrity standards are based on the principles set out above. They describe more specifically, though not exhaustively, the expectations held by Polytechnique Montréal in regard to the people targeted by this policy. These standards apply at all steps of the research process.

7.1    Honesty and integrity in carrying out research activities

All the people targeted by this policy must, among others:

• ensure that the research activities are in keeping with Polytechnique Montréal’s mission;
• assume scientific and ethical responsibility for the choice and carrying out of research activities and see that the work deals appropriately and justifiably with the questions raised by the problem under study;
• in all research activities, respect the principles of rigour and scientific integrity and not commit any act of fraud, falsification or fabrication, among others, when obtaining, recording and analyzing data or information, as well as in the communication of research results;
• make all research results available, visible and accessible, as far as possible, while respecting the policies and rules in effect at Polytechnique Montréal;
• conserve the data and tangible products of the research to make it possible to verify the validity of the research results2;
• respect the confidentiality agreements to which they are committed;
• respect the research-related standards and requirements with regard to human beings, animal experimentation, and the prevention of biological, IT and environmental risks;
• not commit any act of misconduct, deception or dishonesty;
• report, when necessary, errors committed in the research process;
• use only for the planned purposes any confidential information obtained in carrying out an evaluation or expertise provision mandate;
• privilege Polytechnique’s interests in technology transfer operations and research activities carried out for third parties, and fulfil all applicable obligations in respect of the related laws, policies, rules and agreements;
• produce original research documents containing no false declarations or results that are plagiarized, fraudulent, fabricated or falsified.

7.2    Recognition of contributions

All people targeted by this policy must:

• recognize the participation of other researchers by including their names as principal authors or co-authors when the scope of their contribution justifies it;
• recognize appropriately and at their true value all intellectual or physical contributions by students and postdoctoral interns to the research activities, alongside those of other researchers;
• as far as possible, cite all sources and references, and obtain the express authorization of the author(s) of original works or materials to cite them or use them for the purposes of a project;
• respect the Policy on Technological Intellectual Property and the Copyright Policy.

7.3    Respect and equitable treatment of people

All people targeted by this policy must, among others:

• show open-mindedness appropriate to intellectual exchange and necessary for the furthering of knowledge;
• in keeping with the Québec Charter of Human Rights and Freedoms, show no discrimination based on, among others, race, colour, sex, language, religion, political convictions, national origin or social condition, in regard to the people involved directly or indirectly in the various steps of carrying out or managing the research activities, including in the selection of students and postdoctoral interns, in hiring research staff, or in managing these people;
• exercise their authority, as needed, without abusing their power over the staff assigned to the research and the students and postdoctoral interns;
• offer students and postdoctoral interns research projects that take into account their educational goals.

7.4    Transparent and rigorous use and management of funds

All people targeted by this policy must, among others:

• respect the contractual agreements defining the treatment and work conditions of research staff hired through a grant or research contract;
• respect the conditions of the funding agreement in regard to admissible expenses;
• use public or private research funds for the purposes for which they were granted by the granting agency, donors, funders or research partners concerned, in keeping with the Politique sur l'administration des fonds de recherche (policy on the administration of research funds).

7.5    Declaration of all conflicts of interest

All people targeted by this policy must disclose and declare any real, apparent or potential conflict of interest according to the following procedure.

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8    Procedure for dealing with conflicts of interest in research

The carrying out of research activities may give rise to situations of conflict of interest. A list of examples of situations that may give rise to conflicts of interest is provided in Appendix 1.

The existence of a conflict of interest does not necessarily prevent the person in question from being involved in the situation in which the conflict is taking place or may take place, as long as this conflict is declared, evaluated and managed according to the procedures set out in this policy. These measures preserve and strengthen the climate of trust needed for maintaining Polytechnique’s reputation for integrity and objectivity, and those of its researchers, administrators and staff.

8.1    Management of conflicts of interest

For appropriate management to be possible, it is important that all real, apparent and potential conflicts of interest be declared, examined and resolved in the most objective possible manner in order to meet the expectations of granting agencies and society and to protect Polytechnique Montréal’s interests and reputation.

Polytechnique Montréal and the people targeted by this policy are responsible for taking all necessary measures for the appropriate management of real, apparent and potential conflicts of interest.

It is imperative that Polytechnique receive, at the appropriate time, the information relevant to any conflict of interest situation.

As soon as a real, apparent or potential conflict of interest risks influencing actions or decisions within a research-related activity, everyone targeted by this policy must disclose the facts related to such situation and ask the opinion of their department director or hierarchical supervisor, who determines whether the nature of the conflict of interest reasonably requires, due to the circumstances, that a Declaration Regarding Conflict of Interest (Appendix II) form be submitted. Even if circumstances to not require the submission of the Declaration Regarding Conflict of Interest form, the department director or hierarchical supervisor may require that certain measures be taken to resolve the disclosed situation.

If the department director or hierarchical supervisor has a personal interest in the conflict of interest situation, the person in question must address the person at the next highest hierarchical level.

The request for an opinion is processed as quickly as possible such that measures can be taken to avoid or resolve conflicts of interest or the appearance of such conflicts.

8.2    Role of the department director or hierarchical supervisor

If the department director or hierarchical supervisor determines that the facts disclosed in the Declaration Regarding Conflict of Interest constitute a real, apparent or potential conflict of interest, he or she meets with the person concerned to agree upon measures to resolve or prevent it. They record their opinion in writing in the area provided in the Request for Opinion.

These measures may include, among others:

• the establishment of a supervision process for the situation by independent people;
• the obligation for the person in question, or their family, to divest themselves of their interest in a business or place it in trust;
• the modification of a research project or the terms of a contract;
• resignation from the position of director of the research project or from a position that may influence the direction of the research.

The file is then sent to the Dean of Research and Innovation, who sees that the appropriate measures are taken.

8.3    Confidentiality

All requests for opinions made in keeping with this policy are treated confidentially. A confidential file on all the declarations that have required approval or intervention on the part of the Dean of Research and Innovation is kept at the Research and Innovation Directorate.

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9    Procedure in case of failure to comply

Any failure to comply with this policy constitutes an error or misconduct whose level of gravity and whose damaging or reprehensible character depend on the specific context of each situation.

Complaints of misconduct may come from various sources, both internal and external to Polytechnique Montréal. They may be well-founded or erroneous, honest or in bad faith. Regardless of the motivation, source or accuracy, these complaints, and the way they are treated, may cause damage to the person targeted, to the person who alleges the misconduct, to Polytechnique Montréal, and to the scientific community in general. This is why complaints must be processed with diligence and with respect for the rights of the people concerned.

To protect the privacy of the person targeted by the complaint and to protect its author, all information concerning a misconduct complaint, as well as on the process and conclusions of the preliminary verifications and investigations of misconduct cases, is confidential. This information must be processed in respect of the Act respecting access to documents held by public bodies and the protection of personal information (R.S.Q., c. A-2.1). As such, this information may not be disclosed unless the law authorizes it or the person concerned consents.

Cases of failure to comply are managed as follows:

9.1    Informal process

When the situation lends itself to this, Polytechnique Montréal encourages the people concerned to resolve the problems equitably through frank discussion or with mediation from a colleague.

Cases of failure to comply that are criminal in nature may not be subject to an agreement between the people in question. Such cases must be referred to the appropriate authorities, and Polytechnique Montréal may not stand in their place.

9.2    Submission of a complaint

Any person may submit to the Dean of Research and Innovation a complaint alleging failure to comply with this policy. Complaints must be signed. Anonymous complaints cannot be processed. A complaint must identify the person targeted and contain sufficient facts about the alleged misconduct to permit the evaluation of those facts, and must be accompanied, as appropriate, by relevant documents.

9.3    Preliminary analysis

Once a complaint is submitted, the Dean of Research and Innovation summarily examines the complaint in order to immediately reject any complaints that are futile or that cannot be processed under this policy.

If the complaint is judged futile or unreceivable, the file is closed right away and the Dean of Research and Innovation informs the complainant immediately.
The preliminary analysis of a complaint may also allow for the efficient, equitable resolution of simple cases. In this case, the solution must be agreeable to the people concerned, after which the Dean of Research and Innovation can close the file.

For the preliminary analysis, the Dean of Research and Innovation can be assisted by the department director or the hierarchical supervisor of the complainant, or by any other person who may be useful.

As soon as possible, the Dean of Research and Innovation informs the targeted person of the existence of the complaint, of its content, and of the fact that a preliminary analysis is underway. He or she ensures that the identity of the person who submitted the complaint is not disclosed without consent. If the person who submitted the complaint refuses to have their identity disclosed, the Dean of Research and Innovation decides whether the preliminary analysis must be abandoned or whether the information provided makes it possible to continue the analysis without the benefit of this disclosure.

If appropriate, the Dean of Research and Innovation discusses with the complainant about the opportunity to take special measures to avoid any form of reprisal against them.

If necessary, the Dean of Research and Innovation may take temporary measures to preserve the health or safety of people, or to prevent funds administered by Polytechnique Montréal from being used inappropriately. No disciplinary measures are taken at this step.

When the Dean of Research and Innovation judges that a deeper investigation is necessary, he or she forms an investigation committee and communicates in writing with the complainant, as well as with the person targeted by the complaint, to explain the rules of confidentiality and the way the process will take place.

The preliminary analysis of the complaint must, as far as possible, be carried out within thirty days following its submission.

9.4    Formal investigation

9.4.1 Composition of the investigation committee

The investigation is led by a committee formed by at least three impartial members, who have not taken part in verifying the complaint. The committee members are appointed by the Dean of Research and Innovation and are bound by confidentiality.
The investigation committee is made up of:

• at least one professor chosen by the Dean of Research and Innovation from among the members of the Commission de la recherche (Research Commission);
• one person considered to be a peer of the person targeted by the complaint;
• one person from outside the Polytechnique community.

At the time the investigation committee members are chosen, the Dean of Research and Innovation considers, among others, the subject of the investigation and the advantage of having people with a given set of competencies in a given area of research on the committee.

The Dean of Research and Innovation informs the person targeted by the complaint and the complainant of the composition of the investigation committee. They must, within five business days of receiving this information, provide written notice of any objection, as appropriate, with regard to the impartiality or the possibility of conflict of interest on the part of any member of the committee. The Dean of Research and Innovation takes such objections into consideration and takes the necessary measures.

9.4.2 Mandate of the investigation committee

The Dean of Research and Innovation appoints the chair of the investigation committee and informs its members of the mandate with which they are being entrusted. He or she reminds them of the principles of procedural equity and informs them, as appropriate, of the applicable elements of the law.
The investigation committee chair determines the specific rules regarding the investigation process. The application of these rules must be sufficiently flexible to deal with special situations.

The committee carries out a closed-door hearing. All people taking part in the investigation, as witnesses, advisors or observers must sign confidentiality agreements.

At the end of the investigation, the committee must conclude as to whether or not misconduct took place. Outside exceptional circumstances, the committee submits its report within 120 days following the assignment of its mandate.

At least 21 days before the hearing is held, the committee chair informs the person targeted by the complaint:

• of its decision as to whether or not to recommend that the provisory measures imposed by the Dean of Research and Innovation be maintained, as appropriate;
• of the list of people who should normally be heard;
• of the day, time and location of the hearing;
• of the decision, as appropriate, to record, by audio device or by note-taking, of the hearing;
• of the opportunity for the person targeted by the complaint to present a written statement summarizing his or her point of view;
• of the opportunity for him or her to submit documents or other proof or witness accounts in support of his or her point of view;
• of the opportunity for him or her to read any documents submitted to the committee as elements of proof on the part of the complainant;
• of the opportunity to be accompanied by the advisor of his or her choice, this person’s role being limited to providing advice and not intervening directly during the hearing;
• of the opportunity for him or her to invite people to witness and submit tangible proof in support of his or her point of view;
• of the opportunity to question the witnesses on any aspect of their statements;
• of the opportunity to invite a union or association representative to attend the hearing as an observer, with no right to intervene.

As part of its work, the investigation committee may consult experts and, with the authorization of the Dean of Research and Innovation, incur costs in this regard. A copy of all expertise reports is submitted to the person targeted by the complaint.

If the investigation committee discovers reasonable reason to believe that measures must be taken without delay in order to preserve the health or safety of individuals or to prevent funds administered by Polytechnique Montréal from used inappropriately, it must inform the Dean of Research and Innovation, who will ensure that appropriate provisory measures are put into place.

The person targeted by the complaint must collaborate with the investigation committee members so that the hearing may take place without undue delay and so that the committee may submit its report by the deadline.

9.4.3 Investigation committee report

The investigation committee submits its written report to the Dean of Research and Innovation. The report must conclude:

• that the complaint is unfounded and the file must be closed; or,
• that the investigation has established that a failure to respect the terms of the Policy on Integrity and Conflicts of Interest in Research has taken place.

If, in the course if its work, the investigation committee observes that a situation that does not constitute a failure to respect this policy nonetheless requires corrective measures, it notes this in its report. The Dean of Research and Innovation tells the people responsible what correctives must be applied and sets a deadline for doing so.

Should the committee note that the complaint was unfounded and submitted in bad faith, it informs the Dean of Research and Innovation of this, who sees that appropriate measures are taken.

Unfounded complaint

If the investigation committee concludes that a complaint is unfounded, the file is definitively closed and the Dean of Research and Innovation informs the people concerned immediately. Any reference to the complaint is withdrawn from the file of the person targeted by the complaint.

Founded complaint

If the investigation reveals that the terms of this policy have not been respected, the investigation committee specifies, in its report, the nature of the failure and evaluates its degree of gravity.

9.4.4 Follow-up by the Dean of Research and Innovation

Upon receiving the investigation committee’s report, the Dean of Research and Innovation sends a copy to the person targeted by the complaint and to the complainant.

If the report concludes that the terms of this policy have not been respected, the Dean of Research and Innovation must, as appropriate, share the results of the investigation with the granting agency, donors, funders and research partners concerned, as per the terms set out in the agreements governing their relationships to Polytechnique Montréal.

As appropriate, sanctions or other appropriate measures are taken in respect of the statutes, regulations, collective agreements, protocols and all other agreements applicable to Polytechnique Montréal. The decisions may be reviewed according to a collective agreement, a protocol or any other applicable agreement.

If, in its report, the investigation committee mentions that general administrative corrective measures are required, the Dean of Research and Innovation informs the Assemblée de direction, which ensures that appropriate measures are taken.

If the complaint’s existence has been publicly broadcast and the person targeted by the complaint is not responsible for this, Polytechnique Montréal, after discussion with the person in question, may take reasonable measures to mend the person’s reputation.

Any failure to respect the confidentiality of a complaint may lead to sanctions in keeping with the rules, policies, directives, collective agreements or other applicable standards.

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10    Functional structure

Considering the very nature of this policy and the importance that Polytechnique Montréal places on it, all the people engaged in research activities must assume responsibility for its distribution and application.

10.1    Distribution of the policy and awareness of its requirements

10.1.1 The Dean of Research and Innovation

Polytechnique Montréal, through its Dean of Research and Innovation, communicates and distributes this policy to the people targeted by it, and reminds them of their obligation to read it.

Polytechnique Montréal regularly organizes information and discussion sessions in order to raise awareness, both initial and repeated, among the people targeted by the policy about conflicts of interest and the principles and rules of research integrity that must guide their work.

The Dean of Research and Innovation is responsible for distributing the policy and organizing information sessions.

If, for the application of this policy, the Dean of Research and Innovation is unable to intervene impartially and independently in a given situation, the CEO acts instead of the Dean of Research and Innovation.

10.1.2 Department directors

The department directors collaborate in distributing this policy within their departments. They provide support to the research unit managers in exercising their responsibilities. They advise the people targeted by this policy on all questions regarding research integrity and conflicts of interest.

10.1.3 Research unit managers

The managers of research units (centres, laboratories, groups, etc.) see to the distribution of the principles and rules governing research integrity and the rules on conflicts of interest. With the help of researchers, they contribute to raising research staff awareness regarding these questions.

10.1.4 Researchers

Researchers must remain informed of the principles, standards and rules of research integrity and of the rules on conflicts of interest in effect at Polytechnique Montréal as well as in their field of research and in the granting agencies that finance them. They educate and advise their collaborators as well as the people under their authority.

10.1.5 Research supervisors

Research supervisors educate their students and postdoctoral interns about the various principles, standards and rules of research integrity, as well as the rules on conflicts of interest.

10.1.6 Research collaborators

Research collaborators must see that all the research projects in which they collaborate respect this policy.

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11    General terms

This policy enters into effect at the moment of its adoption by the Board of Directors. It does not replace Polytechnique Montréal’s other policies and directives, nor the terms of the collective agreements dealing with ethics or deontology, but the terms of this policy prevail in regard to research.

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12    Minor changes

Any minor changes to this policy may be made by the Research and Innovation Directorate, which informs the members of the Assemblée de direction.

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13    Bibliography

Politique, règles et procédures sur l'intégrité en recherche et sur les conflits d'intérêts, Université de Sherbrooke, dated May 30, 2006.

Politique relative à l'intégrité scientifique, Université Laval, dated May 15, 1995.

Politique d'intégrité dans les activités de recherche et de création, Université du Québec en Outaouais, dated November 21, 1995.

Politique sur la probité intellectuelle en recherche, Université de Montréal, dated December 13, 2004.

Politique et règles en matière d'éthique et d'intégrité en recherche, École de technologie supérieure, dated June 14, 1995.

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A1    Appendix 1

The following list of examples is not exhaustive. All those targeted by this policy who may find themselves in any of the situations presented below, or in similar situations, may be in a real, apparent or potential conflict of interest situation.

1. They perform outside professional activities that may compromise the exercise of their good judgement as a researcher or the ethical performance of their research tasks or responsibilities at Polytechnique Montréal;
2. They own their own business, which offers consultation services or carries out research contracts, or that manufactures or sells goods or services, when this infringes upon their obligations toward Polytechnique Montréal or harms university research;
3. They hire their close relatives and pay them a salary from within their research funds;
4. They use the services of students, postdoctoral interns, or people employed by Polytechnique Montréal, over which they hold academic or supervisory responsibilities, for purposes other than those directly associated with their research at Polytechnique Montréal;
5. They direct their students or have them carry out research work for their personal advantage to the detriment of their university education;
6. They use Polytechnique Montréal’s resources (staff and services, rooms, equipment, materials) for purposes other than those related to their tasks and responsibilities related to Polytechnique Montréal;
7. They use confidential information or research results to which they have access within the framework of their work with Polytechnique Montréal for personal ends, for outside activities, or for an outside business;
8. They use Polytechnique Montréal’s name in agreements or contracts signed on a personal basis with third parties, in such a way as to lead people to believe that the agreement or contract is signed with Polytechnique Montréal, or they guarantee or are involved in such activities in any way;
9. They use Polytechnique Montréal’s name to obtain compensation or other advantages, or to promote a product, a service, a process or a technology;
10. They accept an undue or disproportionate gift or perk for their personal use from people or businesses doing business with Polytechnique Montréal;
11. They acquire cultural goods for personal profit, the enrichment of private or business  collections under the guise of research or potentially in defiance of the laws of foreign countries;
12. They or their business, or with their knowledge, one of their relatives, benefit from or may benefit from or gain financial advantage from a third party, an outside business or a related business whose activities are related to their obligations as a Polytechnique Montréal researcher;
13. They or their business, or with their knowledge, one of their relatives, are or will be in a position to influence or play a role in a relationship between Polytechnique Montréal and a third party for which they or their business expect to provide professional services or negotiate for other business;
14. They or their business, or with their knowledge, one of their relatives, hold or will hold a management position or act as a member of a board of directors or advisory board for an outside business or organization whose activities are related to their research activities;
15. They are part of a scholarship selection committee and make decisions about student applicant files with a colleague in the same department, a colleague in the same research team or a colleague who financially assists their own research activities;
16. As part of their university functions, they supervise the research of a student working in an area related to the activities of their own business;
17. They are a member of a master’s or doctoral supervision committee (with the exception of research supervisors and co-supervisors) while being involved in the student’s work (for example, as a co-author of published scientific articles or articles being prepared).

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A2    Appendix 2

Before filling out this declaration, please carefully read Polytechnique Montréal’s Policy on Integrity and Conflicts of Interest in Research as well as Appendix 1.
Name of person making the declaration: _____________________________________________________________________________

Department or service: _____________________________________________________________________________

Function: _____________________________________________________________________________

Date: _____________________________________________________________________________
I, the undersigned, declare as follows:
I believe that I am in a real, apparent or potential conflict of interest situation for the following reasons:
_____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________________________________________
(Attach additional pages to this form as needed.)
If the facts described above concern your relations with third parties or businesses, such as in one of the examples set out in points 12, 13 or 14 of Appendix 1 to the Policy on Integrity and Conflicts of Interest in Research, include all the relevant information. This information must include, but is not limited to:

• The names of the third parties concerned, and your relationship to these people;
• Details of the relevant financial benefits (for example: property rights, shares, honoraria, financial compensation, etc.);
• The names of your relatives and your relationship to these people and the general nature of the implications of these relationships;
• The names of students, employees, Polytechnique Montréal employees, and all other people in your service and the nature of these people’s involvement;
• The nature of your activities that consist in providing advice or professional services (including participation in boards of directors or advisory boards or other such entities) and the compensation provided for them;
• All the details of the projected use of Polytechnique Montréal resources.

The Act respecting access to documents held by public bodies and the protection of personal information (R.S.Q., c. A-2.1) includes restrictions on the collection of personal information. If, in order to complete your declaration, it becomes necessary to provide details on your relatives’ interests, this information must come directly from these individuals, and it would be helpful to attach it to your declaration.
Your relatives’ declarations should include the following attestation:

I have read Polytechnique Montréal’s Policy on Integrity and Conflicts of Interest in Research and Appendix 1 thereof. I understand that the information provided in this Declaration Regarding Conflict of Interest is required for the purpose of applying this policy and that the personal information it contains is protected under the Act respecting access to documents held by public bodies and the protection of personal information. I consent to their use for the sole purpose of examining whether or not there is a real, potential or apparent conflict of interest.
In addition, should the dissemination of some information be considered appropriate in order to manage a declared conflict, I understand that I will be consulted and I will have the opportunity to provide informed consent.
________________________________________________   ___________________________
Signature                                                                                      Year, month, day

By this document, I request the opinion of ____________________________________________
regarding the facts set out in this Declaration Regarding Conflict of Interest.
____________________________________       ____________________________________
Signature                                                                    Year, month, day

I, the undersigned, ________________________________, declare that I have read this Declaration Regarding Conflict of Interest.
In my opinion:
    The facts provided do not constitute a conflict of interest situation;

    The facts provided constitute a real conflict of interest situation;

    The facts provided constitute a potential conflict of interest situation;

    The facts provided constitute an apparent conflict of interest situation;
The following measures must be taken to manage the situation:
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
__________________________________________________________________________________________________________________________________________________________
____________________________________       ____________________________________
Signature                                                                   Year, month, day
I, the undersigned, ________________________________, signatory of this Declaration Regarding Conflict of Interest, declare that I agree with the measures described above and I commit to respecting them.

____________________________________       ____________________________________
Signature                                                                   Year, month, day

1 This policy is based on the relevant terms adopted by other university establishments, including the Université de Sherbrooke’s Politique, règles et procédures sur l'intégrité en recherche et sur les conflits d'intérêts adopted by its Board of Directors (resolution CA-2006-05-30-08) on May 30, 2006 and the Université Laval’s Politique relative à l'intégrité scientifique adopted by its Board of Directors (resolution CA-95-44) on March 15, 1995.
2 For example, the documents making up the engineer’s file should be kept for a period of 10 years, according to the directives set out by the Ordre des ingénieurs du Québec (OIQ). The CREPUQ, for its part, requires that work documents used for a research project be kept for a period of at least seven years, or in keeping with the contractual requirements of the granting agencies and partners.