Ethics Charter of the Inserm Foundation

Preamble

Under article 5 of its bylaws, the Inserm Foundation’s “purpose is to contribute directly or indirectly to the development and promotion of Inserm, in all areas corresponding to its missions, and to scientific and technological research in the field of life sciences and health, both in France and internationally”. In addition to initiatives in its own name, Inserm may also host foundations set up to support biomedical research.

In adopting this Code of Ethics, the Inserm Foundation has set out the principles and values that guide its governance, its relations with its partners (patrons, donors and suppliers) and its internal operations.

All the recommendations in this charter apply to the Inserm Foundation in the context of its own activities, but also in its capacity as a host foundation.

ARTICLE 1 - INDEPENDENCE OF THE FOUNDATION

The Inserm Foundation is committed to remaining independent of its benefactors in its strategic choices. Patrons and donors may not dictate the implementation of an action or project, nor exercise control over it. The projects supported, even if they are related to the donors’ fields of activity, may under no circumstances serve to promote their commercial, political, religious or philosophical objectives.

No donation may be used to obtain a specific advantage from Inserm or the final beneficiary, whatever the means used.

ARTICLE 2 - VALUES OF THE INSERM FOUNDATION

The Inserm Foundation promotes professional equality and inclusion. It is committed to combating all forms of discrimination.

The Inserm Foundation is also committed to working towards digital and energy sobriety in its day-to-day activities, and promotes projects that integrate an objective of reducing the ecological and digital footprint of public research.

It supports actions and partnerships aimed at combating global environmental change (in particular climate change and the collapse of biodiversity).

The Inserm Foundation is committed to promoting scientific integrity and the quality of research, on which, according to the Bonn Declaration, confidence in science and democracy depend. It is committed to the fight against misinformation, and promotes Inserm’s actions in the fields of Science by and for society, and participatory research.

ARTICLE 3 - ACCEPTANCE OF GIFTS AND BEQUESTS

The Inserm Foundation is authorized to receive donations and bequests. These financial contributions may come from individuals (cash donations, gifts in kind, donations and bequests, life insurance proceeds, etc.) or from legal entities under private law in the form of sponsorship (in cash, skills or in kind), as well as from legal entities under public law, notably in the form of grants.

With the exception of public subsidies, the Inserm Foundation ensures that financial contributions are eligible for the tax incentives applicable to them. In compliance with current regulations, the Inserm Foundation issues a tax receipt to justify the donor’s or sponsor’s entitlement to the tax authorities.

Contributions from companies or private-sector organizations as part of sponsorship initiatives are covered by specific agreements.

The Inserm Foundation accepts donations only insofar as they enable it to support actions in line with its statutory purpose. The Inserm Foundation does not accept donations or legacies:

  • In the event of strong and legitimate doubt as to the regularity or legality of the donor’s activity, or if there is any doubt as to the source of the funds, or if the Inserm Foundation is unable to identify the individual or legal entity from which the funds originate;
  • If the Inserm Foundation considers that the donor’s activity or investments are contrary to the public health objectives at the heart of Inserm’s activity and are therefore likely to be contrary to its mission and to damage its image. In general, contributions that are likely to damage the reputation of the Inserm Foundation or Inserm, or whose image association could be prejudicial to the Inserm Foundation or Inserm, are not accepted;
  • If the conditions attached to contributions are so restrictive that they are likely to harm the Inserm Foundation’s mission, hinder its proper functioning, or result in disproportionate costs or costs that simply exceed the amount of support granted;
  • If the purpose of the contributions is to direct, influence or use the results and work financed by the sponsorship for personal or commercial purposes;
  • If the financial contributions come from accounts in uncooperative countries or territories.

ARTICLE 4 - ETHICS COMMITTEE

The Inserm Foundation relies on the reflections and guidelines formulated by Inserm’s Ethics Committee.

Where necessary, it calls on a specific ethics committee to advise the Board of Directors in situations requiring special, in-depth investigation, both in terms of accepting donations or sponsorship and in terms of its fund-raising strategy and project financing decisions.

This committee is made up of experts in medical research and its specific ethical aspects. Its members are appointed by the Chairman of the Foundation, after consultation with the Board of Directors.

Its members make a sworn declaration of interests.

ARTICLE 5 - INTEGRITY AND ANTI-CORRUPTION MEASURES

Members of the Inserm Foundation must carry out their mission with honesty and integrity.

All Fondation Inserm stakeholders, directors and employees, are required to :

  • refuse cash gifts ;
  • refuse invitations or gifts, particularly from suppliers, in return for an undue advantage of any kind.

ARTICLE 6 - RULES CONCERNING SUPPLIERS AND SERVICE PROVIDERS

The Inserm Foundation is subject to the rules of public purchasing. It undertakes to respect competition and the fair treatment of its suppliers and service providers, whether or not they are donors. The Inserm Foundation refuses any donation or sponsorship proposal if it is conditional on the purchase of a product or the provision of a service.

More generally, the service providers and suppliers of the Inserm public establishment may not obtain advantages of any kind through a donation or sponsorship to the Inserm Foundation.

ARTICLE 7 - MANAGEMENT AND PREVENTION OF CONFLICTS OF INTEREST

According to the Guide Pratique du Conflit d’intérêt dans l’entreprise (Practical Guide to Conflicts of Interest within the Company ) issued by the Agence Française anti-corruption (French Anti-Corruption Agency): “a conflict of interest is any situation in which there is interference between the position held within a company and a personal interest, such that this interference influences or appears to influence the loyal exercise of the position on behalf of this company”.

The Inserm Foundation has set up a procedure to prevent and manage situations of potential conflict of interest for staff or directors in decisions involving, in particular:

  • relationships with major donors and corporate sponsors;
  • recruitment of employees for the Inserm Foundation;
  • selecting suppliers of goods or services;
  • allocating funds to research units, teams or individual researchers.

Directors of the Inserm Foundation draw up a declaration of interests on their honor, making it possible to take note of any situations of conflict in which they may find themselves during their term of office. This declaration is updated annually. It is given to a person designated as a referent within the Foundation, who keeps it on file and examines the possibility of conflict situations before any Board meeting, in conjunction with the directors. This person submits a report to the Chairman of the Inserm Foundation before the Board of Directors meeting. When a situation of conflict of interest concerning a director is identified, the Board of Directors is informed and the director concerned may not take part in the vote.

Regarding the acceptance of a donation, a director may not take part in the vote if it comes from an entity in which he or she has a direct or indirect interest, or holds a position.

Foundation employees receive regular training in managing and preventing conflicts of interest.

ARTICLE 8 - CONFIDENTIALITY OBLIGATIONS

The Inserm Foundation preserves the confidentiality of the information it holds on all its partners, patrons and donors, as well as foundations created under its aegis.

As the protection of personal data is a priority, the Inserm Foundation undertakes to guarantee its security, confidentiality and integrity during collection, processing and storage, in accordance with current regulations. The processing of personal data is strictly subordinated to explicit and legitimate purposes, and the use of data is precisely and restrictively defined, as is its life cycle.

The Inserm Foundation limits access to the databases it houses to its staff, its subcontractors subject to contractual obligations within this framework and, where applicable, to Inserm, in compliance with the regulations in force. No data held by the Inserm Foundation may be the object of any commercial activity whatsoever.

The persons concerned have rights over their personal data, such as the rights of access, rectification, erasure, limitation of processing, portability and opposition to the processing of the said personal data provided for by the laws and regulations. To exercise these rights, they may contact the Inserm Foundation at PariSanté Campus, 2-10 rue d’Oradour-sur-Glane 75015 Paris and at the following e-mail address: fondation.contact@inserm.fr.

ARTICLE 9 - RESPECT FOR SPONSORS AND DONORS

Fundraising activities carried out by the Inserm Foundation will be respectful of donors, in particular :

  • In canvassing methods, which must cease as soon as the potential donor requests them;
  • In the choice of allocation of the donation, which must be made in accordance with the wishes of the patron or donor, whatever the amount of the contribution. If it proves necessary to modify the allocation of a donation, this will be done in consultation with the patron or donor, as closely as possible to his or her initial intentions;
  • In preserving the confidentiality of the donor’s identity if requested;
  • In the information provided to donors to keep them informed about the use of their donation. In the case of significant contributions to specific projects, the Inserm Foundation may provide detailed information, in a form agreed with the donor or sponsor, on the use of the funding, the progress of the work and the results obtained, as well as their impact.

ARTICLE 10 - NO CONSIDERATION FOR DONATIONS AND RECOGNITION PROGRAM

In accordance with current regulations, the Inserm Foundation does not grant any compensation to sponsors or donors.

The Foundation may, however, implement recognition programs for its patrons or donors. In doing so, it undertakes to strictly respect the principle of disproportionality between any benefits attached to the recognition program enjoyed by a patron or donor, and the amount of the donation.

In all cases, the value of benefits granted in this way may not exceed the equivalent of 25% of the contribution.

ARTICLE 11 - RIGOROUS MANAGEMENT

The Foundation is committed to efficient, transparent and traceable use of its resources, particularly those made available by its patrons and donors. It aims to keep its operating costs within reasonable limits in line with industry practice. In particular, it implements procedures and controls to ensure the quality and regularity of its management.

ARTICLE 12 - TRANSPARENCY

The Foundation undertakes to provide its patrons and donors with reliable, fair, precise and objective information on its general orientations, commitments, choices of action, priorities and the use of funds raised. It will also be transparent about its organization and the names of its directors. To this end, the Inserm Foundation draws up an annual report on its activities and accounts, which can be consulted on request.

The Inserm Foundation finances projects whose scientific evaluation has been carried out within the framework of rigorous processes implemented by the Inserm establishment or the beneficiary. In the event that no favorably evaluated project is able to respond to a funding offer, the Foundation makes sure to issue a call for projects.

The Inserm Foundation has its accounts certified annually by a statutory auditor who attests to the sincerity and thoroughness of the Inserm Foundation’s accounts.