Handling competing interests
The European Medicines Agency (EMA) takes care to ensure that its staff, scientific experts and Management Board do not have any financial or other interests that could affect their impartiality. The Agency has separate policies in place for these groups.
EMA's policy on handling competing interests of scientific committee members and experts allows it to restrict or exclude the potential involvement of an expert in any Agency activity, due to interests in the pharmaceutical industry or in the medical-device industry.
This includes members of EMA's scientific committees, working parties and other bodies.
The Agency requires each expert to provide information on their interests in the pharmaceutical industry and in the medical-device industry in a declaration of interests (DoI).
EMA screens each DoI and assigns it an interest level, based on whether the expert has any interests, and whether these are direct or indirect.
For more information and to view the DoIs of individual experts, see European experts.
EMA uses the information provided to determine if an expert's involvement should be restricted or excluded in specific EMA activities, such as the evaluation of a particular medicine. It bases these decisions on:
- the nature of the interests declared;
- the time since the interest occurred;
- the type of activity that the expert will be undertaking.
The policy reflects a balanced approach and aims to effectively restrict involvement of experts with possible competing interests in the Agency's work while maintaining EMA's ability to access the best available expertise.
It includes measures to take into account the nature of a declared interest before determining the length of time any restrictions may apply:
- non-involvement with a company or product throughout an expert's mandate will result from them having held an executive or lead role in the development of a medicine during previous employment with a pharmaceutical company;
- for the majority of declared interests, a three-year cooling-off period is foreseen, whereby restrictions decrease over time and distinguish between interests that remain current and those within the previous three years;
- there is no cooling-off period if certain types of interest are no longer present, such as financial interests.
Requirements for members of scientific committees are stricter than for experts participating in advisory bodies and ad-hoc expert groups. Requirements for committee chairs and members in a lead role such as rapporteurs are stricter than for other committee members.
Current revision of this policy
The current revision of the policy on handling competing interests of scientific experts and committee members brought it in line with:
- EMA’s new responsibilities in the area of medical devices;
- EMA's reinforced role in crisis preparedness.
Accordingly, this policy now applies to members of EMA's Emergency Task Force (ETF) and Executive Steering Group on Shortages and Safety of Medicinal Products (MSSG), as well as to the Executive Steering Group on Shortages of Medical devices (MDSSG).
The revised policy came into effect on 1 January 2023, following adoption by EMA’s Management Board in December 2022.
Previous revisions to the policy have included the following:
- Restricting involvement in the assessment of medicines by those planning to take up a job in the pharmaceutical industry
- Alignment of the rules on close family members with those for Management Board members
- Requirement for members and alternates of EMA’s Committee for Advanced Therapies (CAT) to declare interests in the biotechnology and medical-device sectors
- Requirement to declare interests in relation to personal or organisational involvement in the re-purposing of a medicine.
The policy takes input from stakeholders into account, including input provided at a public workshop on Best expertise vs conflicts of interests: striking the right balance in September 2013.
EMA has a breach-of-trust procedure in place, which sets out how it deals with incorrect or incomplete DoIs by scientific experts and committee members:
EMA's Management Board endorsed the first version of this procedure in 2012.
EMA updated this procedure in December 2022 to align it with the current revision of its policy on handling competing interests of scientific experts and committee members and to include the other bodies added with this revision.
Standard operating procedure for arrangements for handling of conflicts of interests for European Medicines Agency scientific meetings (PDF/127.29 KB)Adopted
First published: 08/10/2012
Last updated: 08/10/2012
Legal effective date: 08/10/2012
Guidance on the handling of declarations of interests in case of a scientific committee member/other (scientific) forum member’s intention to become an employee in a pharmaceutical company (PDF/87.78 KB)Adopted
First published: 06/05/2015
Last updated: 06/05/2015
Guidance for submission and validation of electronic declaration of interests and electronic curriculum vitae (PDF/1.96 MB)
First published: 05/12/2014
Last updated: 13/11/2020
Procedural guidance on inclusion of declared interests in the European Medicines Agency’s electronic declaration of interests form (for scientific committees’ members and experts) (PDF/284.76 KB)
First published: 20/11/2014
Last updated: 06/05/2015
Legal effective date: 30/01/2015
Rules of engagement for patients’ organisations and their representatives in repurposing activities and impact on involvement in EMA activities (PDF/144.6 KB)
First published: 06/07/2020
Public declaration of interests and confidentiality undertaking of European Medicines Agency scientific committees' members and experts - prefilled sample form (version 4) (PDF/876.67 KB)
First published: 08/12/2014
Last updated: 02/02/2021
Nomination form for European experts (PDF/1.34 MB)
First published: 27/11/2008
Last updated: 05/12/2014
Confidentiality undertaking for observers (PDF/113.9 KB)
First published: 28/09/2006
Last updated: 29/01/2021
EMA's policy on handling competing interests for Management Board members and breach-of-trust procedure align with those for scientific committee members and experts.
Policy 58: European Medicines Agency policy on the handling of competing interests of Management Board members (PDF/222.1 KB)Adopted
First published: 04/01/2006
Last updated: 04/01/2023
Legal effective date: 01/01/2023
European Medicines Agency breach of trust procedure on declarations of competing interests for Management Board members (PDF/136.84 KB)Adopted
First published: 21/06/2012
Last updated: 04/01/2023
All Management Board members must submit a DoI every year. These are publicly available under Management Board members.
The current revision of the policy on handling competing interests for Management Board members came into effect on 1 January 2023.
The policy first entered into force in 2006. Since then, EMA has updated the policy to clarify the restrictions and to align the rules and definitions with the policy for scientific committee members and experts.
EMA's code of conduct extends the requirements for impartiality and the submission of annual declaration of interests (DoIs) to all staff members working at the Agency.
New staff must get rid of any interests they have before they can start to work at the Agency.
The rules on how the Agency handles potential competing interests of staff members are similar to the principles for committee members and experts. They explain the allowable and non-allowable interests for staff, and include controls on the appointment of individuals as responsible for managing the evaluation of medicines.
For more information, see Scientifc experts.
The completed DoIs for management staff are available under Who we are. All other staff DoIs are available on request.
More information is available in the documents below:
The European Medicines Agency code of conduct (PDF/181.54 KB)Adopted
First published: 01/01/2005
Last updated: 21/06/2016
Appendix to the European Medicines Agency code of conduct (PDF/159.86 KB)
First published: 07/02/2022
Decision of the European Medicines Agency on rules relating to Articles 11, 11a and 13 of the Staff Regulations concerning the handling of declared interests of staff members of the European Medicines Agency and candidates before recruitment (PDF/352.77 KB) (updated)
First published: 05/10/2020
Last updated: 03/03/2023
Decision on rules concerning the handling of declared interests of national experts on secondment, trainees, interims and visiting experts of the European Medicines Agency (PDF/62.84 KB)
First published: 17/02/2012
Last updated: 20/03/2017
EMA/78396/2012, Rev. 1
Standard operating procedure for conducting checks for conflicts of interest of the European Medicines Agency employees assigned duties relating to medicinal products for human or veterinary use (PDF/331.42 KB)Adopted
First published: 30/11/2009
Last updated: 16/08/2021
Legal effective date: 15/08/2021
Decision of the European Agency for the Evaluation of Medicinal Products of 1 June 1999 concerning the terms and conditions for internal investigations into the prevention of fraud, corruption and any illegal activity de... (PDF/29.48 KB)Adopted
First published: 01/06/1999
Last updated: 01/06/1999
All EMA staff members must request permission to engage in an occupational activity within a two-year period of leaving EMA.
This rule is based on Article 16 of the Staff Regulations and the European Commission rules on outside activities and assignments and occupational activities after leaving the Service, which apply to EMA by analogy.
EMA's Executive Director or Management Board issues a decision that may impose restrictions on the staff member's intended occupational activity, to mitigate any potential competing interests in future.
As of December 2020, EMA's decisions regarding senior staff members leaving EMA are publicly available in the register below for a two-year period following their end of employment at EMA.
Register of EMA decisions on senior staff members leaving EMA
|Name||Most senior position in|
final three years
|End of EMA|
|Intended occupational activity after EMA||Date of EMA|
|Saint-Raymond, Agnes||Head of International Affairs||30/09/2021||The European & Developing Countries Clinical Trials Partnership (EDCTP)||17/03/2023||Assessment outcome|
|Sweeney, Fergus||Head of Task Force||31/05/2022||World Health Organisation, Department of Research for Health||15/03/2023||Assessment outcome|
|Sweeney, Fergus||Head of Task Force||31/05/2022||Multi-Regional Clinical Trials Center of Brigham and Women's Hospital and Harvard||18/01/2023||Assessment outcome|
|Saint-Raymond, Agnes||Head of International Affairs||30/09/2021||Board member (3 years) of the Concept Foundation||17/02/2022||Assessment outcome|
|Saint-Raymond, Agnes||Head of International Affairs||30/09/2021||World Health Organization Academy||30/06/2022||Assessment outcome|
|Saint-Raymond, Agnes||Head of International Affairs||30/09/2021||The European & Developing Countries Clinical Trials Partnership (EDCTP)||21/07/2022||Assessment outcome|
|Wathion, Noel||Deputy Executive Director||30/06/2021||Guest lecturer at Hasselt University||17/08/2021||Assessment outcome|
|Wathion, Noel||Deputy Executive Director||30/06/2021||Non-remunerated volunteer at Rare Disease Europe (EURORDIS)||26/10/2021||Assessment outcome|
|Eichler, Hans-Georg||Senior Medical Officer||30/04/2021||Consultant at Dachverband der Sozialversicherungsträger, an Austrian public health and social insurance organisation||23/09/2021||Assessment outcome|
|Eichler, Hans-Georg||Senior Medical Officer||30/04/2021||Non-remunerated work as volunteer at Rare Diseases Europe (EURORDIS)||29/04/2021||Assessment outcome|
|Eichler, Hans-Georg||Senior Medical Officer||30/04/2021||Professor of Clinical Pharmacology at the Medical University of Vienna|
Continue non-remunerated role as vice-chair of the Scientific Advisory Council at the Centre for Innovation in Regulatory Science
Continue non-remunerated role as advisor at the Massachussetts Institute of Technology
|Saint-Raymond, Agnes||Head of International Affairs||30/09/2021||Continue non-remunerated role as Scientific Advisor for GAP-f at the World Health Organisation, in which they advise on paediatric formulations for essential medicines.|
Panellist in a session at workshop organised by Nile consulting on 20 October 2021.
For the purposes of this register, EMA defines senior staff as staff members who held any of the following positions during their final three years of service:
- Executive Director
- Deputy Executive Director
- Head of Division
- Head of Task Force
- Head of Legal Department
For more information on EMA's organisational structure including its senior staff, see Who we are.
The Agency's annual reports provide a summary on all staff, including senior staff, that were subject to Article 16 restrictions in a given year. This describes the restrictions that apply for each role. To access this information, use the link below:
Information for staff leaving EMA is available below:
Guidance for usage of application form related to Article 16 of the Staff Regulations (PDF/87.53 KB)
First published: 12/06/2013
Last updated: 15/06/2022
European Medicines Agency privacy statement for the publication of post-employment decisions regarding senior staff (Article 16 of Staff Regulations) (PDF/206.13 KB)
First published: 18/12/2020
Declaration of intention to engage in an occupational activity after leaving the European Medicines Agency (DOCX/167.51 KB)
First published: 01/12/2020
Last updated: 16/02/2021
Best practice guide for staff leaving the European Medicines Agency (PDF/117.84 KB)
First published: 14/04/2014
Last updated: 21/08/2015
EMA/70197/2013 Rev. 1
As of 2015, EMA reviews all of its policies on independence and rules for handling competing interests and their implementation annually, and publishes an annual report.
The reports include results of breach-of-trust procedures, any controls carried out, initiatives planned for the following year and recommendations for improvement.
More information is available in the documents below:
2022 European Medicines Agency annual report on independence (PDF/440.92 KB) (new)Adopted
First published: 21/03/2023
2021 European Medicines Agency annual report on independence (PDF/374.41 KB)Adopted
First published: 18/03/2022
2020 European Medicines Agency Annual Report on Independence (PDF/375.74 KB)
First published: 12/03/2021
2018-2019 European Medicines Agency annual reports on independence (PDF/497.59 KB)
First published: 01/07/2020
2016 and 2017 annual report on independence (PDF/247.95 KB)Adopted
First published: 13/04/2018
Last updated: 13/04/2018
2015 annual report on independence (PDF/243.33 KB)Adopted
First published: 31/01/2017
Last updated: 31/01/2017