Managing conflict of duties
Serving on boards, committees, and other bodies for NRC
The new NRC Conflict of Interest and Post-Employment Policy (COI-PE) (2015) recognizes that, separate from a “conflict of interest” which most often revolves around the concept of personal benefit, we can encounter a “conflict of duties.” This is a conflict that arises as a result of concurrent or competing responsibilities in an outside position, such as membership on an external committee or board on behalf of NRC as described below. NRC researchers could also act as adjunct professors as an extension of their duties at NRC. The principles reflected in the guidelines below would apply equally in such circumstance.
With respect to service on committees and boards, NRC employees adhering to the guidelines below are not required to submit a Conflict of Interest (COI) Declaration. They can, however, do so or otherwise consult the NRC Secretary General’s Office (NRC-SGO) for further guidance via this email address Conflict of Interest/Conflits d'Intérêts (NRC/CNRC).
- When an outside organization seeks NRC technical or strategic management expertise (whether via membership on a board, on a committee, or through other means) and intends to pay a per diem, honorarium, or fee, the best practice is to negotiate a contract with NRC, not an individual employee, and to have payments made to NRC.
- The employee, the employee’s supervisor, and other management (as described below) should approve the activity after ensuring that the organization involved has a robust governance infrastructure of terms of reference, defined roles, dedicated secretariat support, processes and, when relevant, insurance or other arrangements to limit director liabilities. If any payments are made for this service to the employee, these funds are to be turned over to NRC in accordance with financial management policies.
Who should approve?
Because of the demands on employee working time, the potential for organizational conflicts and fiduciary implications of official participation in outside entities, NRC employees should not only have agreement from their supervisors but also senior management as follows.
Membership on the Board of Private Sector Firm
- Not generally permitted, and only with approval of the President.
Advisory Committee to a Private Sector Firm
- Supervisor and Vice-President approval
Board of Not-For-Profit Association or Organization
- Supervisor and Vice-President approval
Advisory Committee to Not-For-Profit Association or Organization
- Supervisor and General Manager/Director General/
or Vice-President/Executive Director (NRC Industrial Research Assistance Program) approval
After accepting appointment
All NRC employees serving in such roles as part of their official duties should:
- Only accept hospitality that is infrequent and of minimal value within the normal standards of courtesy or protocol an decline any gifts or other tokens for service that are not consistent with the NRC COI-PE Policy;
- Refrain from disclosing confidential NRC business information and act within the frame of established NRC business practices;
- Not use their role as a member of an outside body, even if an extension of official duties, to influence a decision to further private interests; and
- Share these Guidelines with the organization concerned.
All NRC employees serving in roles, as described above, as part of their official duties should:
- Remove themselves from any discussion, decision, debate or vote if they would be in a conflict with their primary NRC duties;
- Declare a bias if NRC’s interests are indirectly affected by the external body’s discussions and seek guidance at the committee or board level; and
- Ask that actions such as the above declaration or recusal from discussions be recorded in the relevant documents, such as minutes or reports.
Personal service – Outside of official NRC duties
External committees, boards, and other bodies
NRC employees considering similar positions with external organizations - separate from the NRC official duties and on their personal time - are asked to consult the NRC COI-PE Policy and file a Conflict of Interest Declaration accordingly.
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