CanCertainty’s Corporate Transparency and Code of Conduct

CanCertainty’s Corporate Transparency and Code of Conduct (the Code) is a policy adopted by CanCertainty and it’s secretariat, Kidney Cancer Canada, (the Charity) regarding financial relationships with commercial entities. The Code is intended to minimize the impact of real, potential or perceived conflict of interest that may arise when the Charity accepts financial support from a company.

Definitions

The following definitions apply to terms used:

‘Charity’ in this Code refers to Kidney Cancer Canada and CanCertainty.
‘Company’ refers to a commercial entity providing, or seeking to provide, funding to CanCertainty. This definition includes agents of the company.
‘Funding’ refers to any of the five categories of financial support outlined under the Policies section.

Guiding Principles

The CanCertainty Transparency and Code of Conduct is based on the following guiding principles:

Patient Interests: All activities of CanCertainty are conducted in accordance with the best interests of patients and caregivers.
Integrity and Scrutiny: CanCertainty shall perform its duties in a manner that withstands public scrutiny.
Respect: CanCertainty respects the stakeholder relations policies of a company with which it is involved.
Impartiality and Transparency: CanCertainty ensures it is impartial and objective and that corporate funding decisions are made based on merit. CanCertainty is as open as possible about all actions that it takes and advice that it provides.
Accountability: CanCertainty accepts accountability for its compliance with the Code and ensures that any company with which it is involved is familiar with the Code.

Policies

Conflicts of interest may arise in a mutual relationship where one party has the capacity to exert undue influence over another. The following policies have been developed to ensure that relationships of CanCertainty and its corporate funders are ethical, transparent and reflect positively on both the Charity and funders.

1. FUNDING: CATEGORIES

Five funding categories are included in the Code:

1.1 Project funding – where CanCertainty establishes a collaboration with a company to undertake a project relating to an issue of mutual interest, the following will apply:

CanCertainty maintains editorial control over all materials produced in connection with the project.
The sponsor will be acknowledged, in accordance with their policies and governed by CanCertainty’s policies.
CanCertainty will not endorse or promote individual products or services.
CanCertainty and the company may both benefit from the relationship.

1.2 Sponsorship – where a company funds a single activity such as an external meeting or newsletter, the following will apply:

The company is not involved in the design and planning for the activity for which the sponsorship is granted.
CanCertainty maintains editorial control over all materials or meeting programs and has sole discretion on the meeting attendees.
CanCertainty will not endorse or promote the company’s products or services.
The sponsor will be acknowledged, in accordance with the CanCertainty’s and Kidney Cancer Canada’s transparency principles.
CanCertainty and the company may both benefit from the relationship.

1.3 Unrestricted grants are defined where all the following apply:

The company is not involved in the project for which the grant is used.
The grant will be acknowledged; however, the company’s logo is not used.
CanCertainty controls the wording and position of the acknowledgment.

1.4 Financial donations and in-kind support may be offered to CanCertainty.

In this case the CanCertainty will acknowledge the name of the corporate donor on its website if the amount of support is greater than 10 percent of the Charity’s total annual revenues. The monetary value of in-kind support over $1,000 should be included in the total amount of the support.

1.5 Support of research activities

Financial support for research projects may be provided by a company for administration by CanCertainty. This may take the form of an unrestricted grant or project funding and the respective policies apply to each form of support.
The company may not have representation on the project steering committee, and CanCertainty maintains control over the choice of research, study design and publication of results.
The sponsor(s) of any research activities will be acknowledged at the presentation and publication of results.

2. POLICIES FOR THE CHARITY

CanCertainty adheres to the following policies when accepting project funding, sponsorship, grants or donations from companies. :

2.1 Before accepting funding from a company, CanCertainty must conduct due diligence to satisfy itself that:

There is strong reason to believe that the donation, grant or sponsorship will result in benefit to CanCertainty and to the patients and caregivers it serves.
The company’s type of business, its corporate governance policies and its reputation in working with CanCertainty do not present any cause for concern.
CanCertainty will not knowingly accept any type of funding from a company that primarily produces or primarily sells commercial tobacco products or primarily receives funding from their sales.

2.2 CanCertainty will maintain its independence of action

The content of communications originating from CanCertainty, such as patient submissions for drug reviews, policy submissions, information for patients, caregivers and the public, newsletters and presentations must be developed without participation of corporate sponsors.
Submissions for drug reviews or policy recommendations will not be shared or reviewed with sponsors in advance.
CanCertainty will not endorse or promote individual products or services by brand name. Advocacy activities, such as making patient submissions for drug reviews or petitioning governments to fund a therapy, are not considered promotion because these activities are intended to improve access to the therapy, rather than recommend that it be prescribed. Similarly, providing educational information on available therapy options is not considered promotion.

2.3 CanCertainty will maintain mutually respectful and transparent relations.

CanCertainty and/or Kidney Cancer Canada will sign a written agreement with all companies outlining each partner’s contribution and responsibilities. The company and CanCertainty must agree to abide by each other’s codes of conduct.
A company’s support will be acknowledged transparently and appropriately.

2.4 CanCertainty will proactively limit influence.

CanCertainty, where possible, should seek a diversity of funding sources and should not allow any one corporate sponsor to contribute more than 50 per cent of CanCertainty’s total revenues for the year, including the value of in-kind services.

3. POLICIES FOR COMPANIES

CanCertainty will not embark upon or continue with any sponsorship, grant making or collaborative venture that might damage its reputation or result in the dissemination of biased and inaccurate information. Therefore, when working with CanCertainty, companies are expected to adhere to the following guidelines:

3.1 CanCertainty must be consulted whenever and wherever its name is used. Approval must be sought, in writing, for any copy produced which refers to an initiative of CanCertainty that is supported by the company.

3.2 At no time can CanCertainty’s logo be used without express permission.

3.3 At no time can press releases be issued which refer to CanCertainty without the Charity’s prior approval. Likewise, suggested quotes can be prepared but must always be agreed to, by the CanCertainty.

3.4 CanCertainty retains a veto over all materials produced in connection with an initiative.