Consultation outcome

Annex 3: Other relevant interests

Updated 8 September 2022

Other relevant interests

4.7 It is not only financial interests in the pharmaceutical industry that are relevant. A wide range of other matters may also be considered to be relevant, depending on the circumstances and matters under consideration by a committee on which an individual serves, and could include non-financial interests. There are no hard and fast rules concerning “other” interests that need to be declared. In considering whether an interest is relevant and therefore should be declared, the guiding principle must be whether the matter might reasonably be perceived as affecting a member’s impartiality. Some examples of matters that might fall under this heading 7 are set out below. These are not exhaustive, and individuals should always seek advice from the MHRA Secretariat if they are in any doubt about whether or not a matter is relevant:

  • An individual, or his department, has done research work relating to a particular product, or class of products. Although the research has not been funded by any particular pharmaceutical company, the research has taken a particular line e.g., in relation to the safety of the products, or their efficacy;
  • An individual has made public statements (either favourable or unfavourable) about a particular company, or product, or class of products or about a competitor’s product or class of product;
  • The relevant committee is considering whether a product should be reclassified, for example, from prescription only, to a pharmacy medicine, and the individual has a particular interest in the reclassification being made, for example, because he is a retail pharmacist and he will benefit financially;
  • An individual participates in, or is connected with, a charity or pressure group that would have an interest in the outcome of the advice being given;
  • An individual has a family member who suffers from an illness who would benefit from treatment if a product under discussion were to be authorised;
  • An individual has a family member who has suffered a severe reaction or other problem as a result of treatment with a product under discussion;
  • Matters relating to persons who are not immediately family members, but are closely connected with the committee expert, for example, adult child no longer living in the same household, or non-family member whose work or other interests are closely associated with the pharmaceutical industry and which could reasonably be perceived as affecting the individual’s impartiality. An example might be where a committee is giving advice in relation to a product and a close family member or friend has had a major development responsibility for that product;
  • Interests in a company manufacturing the delivery system (for example, syringes or other medical equipment) for a particular medicinal product;