Conflicts of Interest
1. Does TCPS 2 provide guidance about thresholds for financial conflicts of interest?
TCPS 2 does not advocate setting thresholds to determine financial conflicts of interest. The salient factor to consider in assessing financial conflicts of interest is the degree to which the interests conflict, not the monetary value involved. TCPS 2 also does not advocate limiting interpersonal conflicts of interest by closeness of familial relationship, as the conflicts of interest may occur with any degree of familial relationship, friendship, or partnership. Articles 7.3 and 7.4 require the disclosure and management of all real, perceived and potential conflicts of interest by REB members and researchers. It is desirable for institutions to address financial conflicts of interest in their policies in accordance with guidance in Article 7.1.
2. Do REB members and researchers have to disclose real, potential or perceived conflicts of interest posed by their investments in mutual funds?
Articles 7.3 and 7.4 state that REB members and researchers must disclose any real, potential or perceived conflicts of interest. In the case of mutual funds, much depends on the amount of control the individual has over these investments. In the case of a self-directed mutual fund (or any other type of self-directed investment), the investor has first-hand knowledge of the products and companies he/she is investing in. It would be the investor’s responsibility to identify any risk of real, potential or perceived conflicts of interest posed by any investment to any research project he/she is involved in, either as a researcher, or as an REB member. Investments that are not self-directed, and of which the investor has no direct knowledge, do not require detailed conflicts of interest disclosure.
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