“The part-time members of the governing body as well as staff of the NIHR can engage in other paid and unpaid activities. As referred to in section 17(4) of the NIHR Act and in accordance with Section 13(1) of the Autonomous Administrative Authorities Framework Act “a member of an autonomous administrative authority may not perform outside work that is undesirable with a view to the proper performance of his job or the maintenance of his independence or of confidence therein”.

The NIHR reports that, where a member wishes to engage in such activities, an internal discussion occurs and a decision is made by the governing body of the institution. Further, as it relates to staff, the NIHR reports that relevant details relating to other such activities are made publicly available on its website.

However, there do not appear to be additional provisions – in legislation, regulation, or another binding administrative guideline – that provide further guidance on what types of activities constitute a conflict of interest or the process by which a determination would be made about the existence of such a conflict.

The SCA notes that the Paris Principles require an NHRI to be independent from government in its structure, composition, decision-making and method of operation. The avoidance of conflicts of interest protects the reputation, and the real and perceived independence of an NHRI.

The SCA encourages the NIHR to advocate for the development of further binding guidance with respect to what constitutes a conflict of interest and the process by which a determination would be made about the existence of such a conflict.”