Policy 01 — Conflict of Interest Policy

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PHIG Policy Framework v1.2 · Policy 01 · Adopted 1 September 2026 · References: Financial Regulation (EU, Euratom) 2024/2509, Art. 61; EU Model Grant Agreement Art. 12 (Conflict of interests); Horizon Europe Annotated Grant Agreement; EU Rules on Participation

1. Purpose

This policy ensures that decisions of the Public Health Institute of Georgia (PHIG) — verdicts, assessments, accreditation readiness reports, editorial decisions, grant management, procurement and recruitment — are taken on their merits and are seen to be. It defines what a conflict of interest is, who must declare one, how it is recorded, and how it is managed.

2. Scope

Applies to every person acting for PHIG or any platform of its network (the Georgian Medical Journal, GMJ News, GMJ Academy, the Georgian Institute of Labour Studies, Sheni Labs, SupplementIndex, and PHIG’s role in Accréditation Sans Frontières and the Accreditation Canada – Georgia office): Board members, the Chair/Director, paid staff, consultants, members of scientific and editorial committees, reviewers, members of expert pools (named or unnamed), volunteers and anyone engaged under a grant or contract.

3. Definitions

• Conflict of interest: a situation in which a person’s private interest — financial, professional, family, political, personal or any other shared interest — could improperly influence, or appear to influence, the impartial and objective performance of their functions for PHIG.
• Private interest includes employment, consultancy, shareholding, grants, fees, hospitality, honours, memberships, and the interests of a spouse, partner, child, parent, sibling or close associate.
• Apparent conflict: a situation that a reasonable, informed observer would consider likely to compromise impartiality, even if no actual influence occurs.
• Potential conflict: a situation that would become a conflict if a foreseeable decision arose.

4. Policy

1. Every person within scope declares their interests in writing on joining and at least annually, and updates the declaration within 30 days of any change.
2. Before any specific assignment — a product verdict, a peer review, an accreditation readiness assessment, a procurement evaluation, a recruitment panel, a grant decision — the person confirms in writing that no conflict exists for that assignment, or declares one.
3. A person with an actual, apparent or potential conflict does not take part in the preparation, discussion, decision or communication of the matter, and is recorded as having withdrawn.
4. No person reviews, assesses or decides on a product, service, manuscript, course or organisation of a company or institution that employs them, has employed them in the previous three years, pays them, or in which they or a family member hold an interest.
5. Gifts, hospitality or benefits from any party with an interest in a PHIG decision are refused, except promotional items of negligible value; anything above the value of EUR 30 is declared and registered.
6. Declarations are held in a register kept by the Director; Board and committee declarations are published, with the person’s consent where the person is not publicly named under the expert pool policy.
7. In EU-funded actions, PHIG applies in addition the conflict-of-interest provisions of the grant agreement, declares any conflict to the granting authority without delay, and takes the measures the authority requires.

5. Responsibilities

• Board: adopts the policy, reviews the register annually, decides on conflicts involving the Director.
• Director: maintains the register, decides on individual cases, reports to the Board.
• Committee chairs and editors: apply the policy to their members and reviewers, record withdrawals in minutes.
• Every individual: declares, withdraws, asks when unsure.

6. Procedure

1. Declaration form completed (annex A) and signed; filed in the register.
2. Assignment-specific confirmation recorded with the assignment file.
3. Where a conflict is identified: the Director (or the Board, for the Director) decides whether withdrawal, replacement, additional review or disclosure resolves it; the decision is minuted.
4. Undeclared conflicts discovered later are investigated under the Anti-Fraud Policy; decisions affected may be re-opened and corrected.

7. Breaches

Failure to declare, or participation despite a conflict, is misconduct. Consequences range from a written warning to removal from the pool, committee or position, termination of a contract, and reporting to the granting authority where EU funds are concerned.

8. Review

Reviewed by the Board every two years and after any incident.

Annex A — Declaration of interests (summary of fields)

Name · role at PHIG · current employment and positions held · paid activities in the last three years · financial interests above EUR 1,000 in any company in the health, pharmaceutical, supplement, cosmetics, laboratory, accreditation or tobacco sectors · grants and fees received from industry · memberships and honours · interests of close family · hospitality received · statement that the declaration is complete · signature and date.

Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).