Table 3 Conflict of interest policies and practices in key public pharmaceutical committees in SEAR countries
| Â | Regulation | Selection | Pricing | Public procurement |
|---|---|---|---|---|
Bangladesh | Quality Policy exists [33] | No information [34] | No information | Procurement Rules and Code of Ethics exists [25] Individual written COI declaration Collective declaration of impartiality Replacement of members with COI Prohibition of gifts, payments, hospitality to members Debarment for violation of COI rules |
Bhutan | Individual written COI declaration prior to all meetings [29] Members with COI must abstain from relevant work [29] Members avail themselves of remuneration for attending meetings [29] Oversight of policy implementation by Anti-Corruption Commission Civil servants prohibited from: Working in private sector Accepting meals from the private sector | Individual written COI declaration prior to all meetings Replacement or recusal of members with COI Oversight of policy implementation by Anti-Corruption Commission Civil servants prohibited from: Working in private sector Accepting meals from the private sector | Individual written COI declaration prior to all meetings Replacement or recusal of members with COI Oversight of policy implementation by Anti-Corruption Commission Civil servants prohibited from: Working in private sector Accepting meals from the private sector | Procurement Rules and declaration form [26] Individual written COI declaration prior to all meetings Replacement or recusal of members with COI Disclosure verified by procuring agency Members sign Integrity Pact [35] Prohibition of bribes, consideration, gifts, rewards, favours, or any other material or immaterial benefit or advantage Tender process is open and transparent Grievances mechanism Oversight of policy implementation by Anti-Corruption Commission Civil servants prohibited from: Working in private sector Accepting meals from the private sector |
DPRK | No information | No information | No information | No information |
India | Individual written COI declaration [22] Subject experts selected from expert bank [36] | No information [37] Individual written COI declaration | N/A – largely at the state level | |
Indonesia | Individual written COI declaration on annual basis Individuals with COI are recused from drug evaluation and committee meetings | Transparent, evidence-based process for medicines selection [38] Individual written COI declaration Pharmaceutical industry cannot submit formulary requests directly | Excludes pharmaceutical industry employees and representatives Individual written COI declaration | No information |
Maldives | Transparency guideline exists [39] Individual written COI declaration Members with COI must abstain from relevant work Agreement to abstain from private sector employment Civil servants are provided a non-practice | N/A – responsibility of regulatory staff | No information | |
Myanmar | No information | No information [42] | No information | No information |
Nepal | Civil servants not allowed to work in private sector | Civil servants not allowed to work in private sector | Industry representatives must declare COI and abstain from relevant work | Public procurement Code of Conduct [43] Bidders and consultants must provide written COI declaration Prohibits inducements to procurement officials Officials must refrain from COI Officials cannot work for an entity with which they have had procurement dealings until 2 years after retirement Recusal of officials from procurement proceedings where family members are involved Public Procurement Monitoring Office provides oversight and enforcement |
Sri Lanka | Code of Conduct present Terms of reference exist [30] COI defined Individual written COI disclosure upon selection and from ‘time to time’ thereafter Disclosures recorded in committee minutes Committee members ‘should not’ have any COI Members with COI must abstain from relevant decision-making or other work No employment by pharmaceutical industry 3 years prior or 3 years following membership Subject matter experts do not have voting rights | None | Individual written COI disclosure required | Individual written COI disclosure required |
Thailand | Individual written COI disclosure required [44] Disclosures verified by secretariat | Codes of ethics for medicines selection processes Excludes pharmaceutical industry employees, owners and executives Individual written COI disclosure required for NLEM working group experts, [45] secretariat and NLEM subcommittee during committee development and at each meeting NLEM members with any business interest in the medicine or intervention must abstain from relevant decision-making HITAP members must annually declare COI [46] HITAP members prohibited from receiving financial benefits from private, for-profit companies based on the organisation’s codes of conduct [46] COI policy is regularly reviewed and revised as needed | Individual written COI disclosure required [15] | N/A – procurement largely de-centralised |
Timor-Leste | No information [47] | No information | Anti-corruption commission provides oversight |