Expert Panel for Fragrance Safety Conflict of Interest Statement
Amended September 21, 2016
1. Act in Utmost Good Faith. To further the mission of the Research Institute for Fragrance Materials (“RIFM”) and the Expert Panel for Fragrance Safety (the “Expert Panel”) and to act responsibly for the benefit of the fragrance and flavor industry and consumers of its goods and services, each member of the Expert Panel (“Member”) shall exercise the utmost good faith in the performance of his/her responsibilities as a member of the Expert Panel. The term “the fragrance and flavor industry” includes manufacturers, suppliers, distributors, vendors, customers, partners, affiliates, consultants and advisors in the field of fragrances and flavors.
2. No Personal Benefit. In performing his/her duties, a Member should not be influenced by desire for personal benefit for himself/herself or for his/her family members, other relatives, friends and business colleagues. Each Member shall not use his/her position, or knowledge gained therefrom, for personal benefit for himself/herself or for his/her family members, other relatives, friends and business colleagues.
3. No Conflict of Interest. Each Member shall avoid both a conflict of interest and the appearance of a conflict of interest. The term “conflict of interest” means a situation in which a Member’s professional judgment or behavior concerning a matter before the Expert Panel has been or potentially may be improperly influenced by a personal interest (such as for financial gain). Situations that could cause a conflict of interest include having an employment, consulting, or financial relationship with a person or entity in the fragrance or flavor industry or accepting gifts or money from persons or entities in the fragrance and flavor industry.
4. No Employment or Consulting. A Member shall not be employed by or engaged as a consultant, advisor or other independent contractor, directly or indirectly, by or for a person or entity in the fragrance and flavor industry with respect to any fragrance ingredient.
5. No Commercial Ties. Each Member shall not have any commercial ties to persons or entities in the fragrance and flavor industries with respect to any fragrance ingredient. The term “commercial ties” means a significant financial interest. Commercial ties exclude any work by a Member pursuant to grants, funding or other support from associations connected to the fragrance industry, provided the Expert Panel is informed of such support and the support is provided to the Member’s institution and not personally to the Member.
6. Agreement to this Conflict of Interest Statement. Upon becoming a member of the Expert Panel, each Member shall sign and date a statement that the Member has read this Conflict of Interest Statement, understands its terms, and agrees to comply with its requirements.
a. General Disclosure Statement. Upon becoming a member of the Expert Panel and once each year thereafter, each Member shall complete, sign, and date a statement that accurately discloses each Disclosure Situation. In the event of a material change of circumstance that makes a Member’s disclosure statement inaccurate or incomplete and necessitates supplementing such statement, the Member promptly shall provide a signed and dated supplemental disclosure statement that accurately discloses each Disclosure Situation. Each disclosure statement and supplemental statement and the information provided in these statements will be treated as confidential.
b. Meeting Disclosure Statement. Before each meeting of the Expert Panel, each Member shall disclose any possible Disclosure Situation related to the subject matter of the meeting.
c. Disclosure Situation. The term “Disclosure Situation” means:
i. The Member or the Member’s family member has (A) an employment relationship with a person or entity in the fragrance and flavor industry, (B) a consulting, advisory or other independent contracting relationship with a person or entity in the fragrance and flavor industry, or (C) has commercial ties to a person or entity in the fragrance and flavor industry, excluding ownership of an indirect interest in an entity in the fragrance and flavor industry, such as ownership through a mutual fund or other indirect, non-controlling interest.
ii. The Member or, to the best of his/her knowledge, the Member’s family member, has received licensing fees, honoraria, stock, stock options, or other equity interests, travel expenses, gratuities, gifts, entertainment, loans, or money with a value in excess of $2,000 per year from any person or entity in the fragrance and flavor industry.
iii. The Member or, to the best of his/her knowledge, the Member’s family member has served as an officer or director of, has been employed or engaged as a consultant, advisor or other independent contractor, directly or indirectly, by, or has done research sponsored by or on behalf of any person or entity in the fragrance and flavor industry.
iv. The Member becomes aware of any development in his/her life or in the life of a family member that may compromise the integrity of RIFM or the Expert Panel.
The term “family member” means a spouse, partner, or significant other, son or daughter, and parent.
d. Meeting Disclosure Procedure. Where, in the sole judgment of the individual Member the situation involves sensitive or confidential information, a meeting’s disclosure may be limited initially to legal counsel for the Expert Panel, who will then decide whether further disclosure or recusal by the Member with respect to that matter is required. In no instance shall a Member having a possible conflict of interest on any matter vote on the matter. When a Member is barred by actual or apparent conflict of interest from voting on a matter, ordinarily the Member should not participate in or attend discussion of the matter at an Expert Panel meeting.
e. Failure to Disclose. Failure of a Member to comply with the Expert Panel’s disclosure requirements may be considered cause for removal of the Member from the Expert Panel.
8. Public Activities. Members of the Expert Panel are viewed as experts and are often invited to speak to gatherings of the academic community or the general public. To avoid possible confusion or misunderstanding, Members who address such groups should clearly indicate whether they are speaking on behalf of the Expert Panel, as private individuals or as representatives of other institutions or entities.