Policy on corporate relationships
As currently approved by the SIR Executive Council
This policy pertains to funding for society programs, as sought by SIR staff and volunteers, not to relationships between corporations and physician members of SIR.
The Society of Interventional Radiology (SIR) greatly values and relies upon financial and in-kind support from reputable corporations to further SIR's mission to advance the science and art of interventional radiology and promote community health, patient welfare and public education in this medical field. In many instances, financial support from corporate sponsors enables SIR to engage in continuing medical education programs, public education initiatives and other activities that could not otherwise be pursued. The following guidelines were established to ensure that all of SIR's corporate support arrangements advance its mission and strategic goals, serve the best interests of the membership, retain SIR's independence and avoid conflicts of interest.
1. Definition of corporate arrangements. For the purpose of these guidelines, "corporate arrangements" shall mean transactions in which SIR receives funds or other contributions from a commercial organization, either as a direct donation in support of an SIR program or activity or as part of a collaborative public education program or event.
2. Consistency with SIR's mission. When appropriate and desirable, SIR may participate in corporate arrangements to support activities that will further SIR's mission to improve health and quality of life through the practice of interventional radiology and to promote education, research and communication in the field, while providing strong leadership in the development of health care policy. SIR shall exercise sole discretion in choosing its corporate supporters.
3. Review and approval. Any proposed corporate arrangements, other than those involving just an unrestricted donation of funds, must be reviewed and approved by SIR's Executive Council or its appointed leaders to ensure that such arrangements would have no potential influence on SIR policies, are consistent with SIR's mission and goals, do not pose a conflict of interest and in no way effect the objectivity of the association, its members, activities and programs. SIR executive staff will review and approve prior to publication or dissemination all marketing materials bearing SIR's name, logo and/or other identifying information for compliance with these principles and guidelines.
4. No endorsement. Participation in a specific corporate arrangement should not in any way imply SIR's endorsement of that corporation's general policies, products or services, nor imply that SIR will exert any influence to advance the corporation's interests outside the substance of the arrangement itself. SIR's name, logo and/or identifying information may not be used in a manner that would express or imply SIR's endorsement of the corporation or its policies.
5. Written agreement. The terms, conditions and purposes of the financial or in-kind support will be documented by a signed agreement between the corporate supporter and SIR. In entering into a corporate agreement under this policy, SIR will ensure to the extent feasible that taxable and nontaxable payments are separately identified and itemized in the agreement.
6. No free advertising or return benefit. Supporters will not be entitled to receive free advertising (as that term is defined by the Internal Revenue Code [IRC] or Internal Revenue Service [IRS] rules and regulations) or other substantial return benefit from its contribution other than appropriate acknowledgments. SIR may, in its sole discretion, provide nonqualitative acknowledgments of supporter's contributions in its regular periodicals; however, supporters will not be entitled to such acknowledgments as a condition of their contributions.
7. Acknowledgments. Consistent with the corporate support provisions of the federal tax laws, SIR may permit program materials and activities to include acknowledgments of financial and other support from organizations. Such acknowledgments may identify and describe the company's products or product
lines in neutral terms and may include the supporter's name, logo, slogan, locations, telephone numbers or website addresses as long as such acknowledgments do not include (a) comparative or qualitative descriptions of the company's products, services or facilities; (b) price information or other indications of savings or value associated with the company's products or services; (c) a call to action; (d) an endorsement; or (e) an inducement to buy, sell or use the supporter's product or service. Any such acknowledgments will be created, or subject to prior review and approval, by SIR.
8. No product promotion. Organizations are not permitted to advertise, market or otherwise promote specific products and services in connection with their support of SIR-related programs and activities.
9. No contingent payments. SIR will not enter into a corporate arrangement where the amount of payment by the corporation is contingent upon attendance at an event or other measures of public exposure.
10. Free items to members. SIR will carefully scrutinize any corporate arrangements that give an organization the right to provide something of value to SIR members or other physicians to ensure that the giveaway item or service is of nominal value and is not tied to the volume or value of physician purchases of the supporter's products or services.
11. CME rules. SIR maintains complete control of the content and speakers at any supported activity or event. Commercial supporters will not control the planning, content or execution of the activity. Commercial supporters may not attempt to direct or influence the faculty or content of SIR programs. SIR will follow the "Standards for Commercial Support of Continuing Medical Education" of the Accreditation Council for Continuing Medical Education (ACCME), which can be found at the following address: accme.org, as well as all applicable FDA rules and guidance regarding industry support and/or promotion of off-label use.
12. SIR's authority. SIR must maintain final authority on all collaborative projects and corporate arrangements. Direct contact between a supporting company and a SIR member(s) regarding a collaborative program/activity between SIR and that company shall be made only as approved by SIR.
13. Reports. Reports on SIR corporate activities will be regularly presented to SIR's Executive Council.
14. Exclusivity. Whenever possible and feasible, SIR shall seek funding for programs from a variety of sources. It is understood, however, that occasions may arise when support of a specific event, publication or service from a single source is appropriate. SIR will exercise special caution so that in circumstances when single support is granted, SIR avoids conflicts of interest and guards against any perception of conflict of interest.
15. Indemnification/insurance. Where appropriate, SIR will ensure that organizations agree to appropriate indemnification and hold harmless provisions to protect SIR and its officers, directors, employees and agents against any liability that might arise out of the organizations' acts or omissions with respect to a particular arrangement, including, but not limited to, any acts or omissions relating to the marketing, sale, dissemination and/or use of a corporate supporter's products. SIR may also require corporate supporters to add the society to the supporter's liability insurance where appropriate.
16. Termination. SIR reserves the right to terminate any corporate arrangement if the supporter or its representatives or agents engage in any conduct, including, but not limited to, product promotion activities that would lead SIR to reasonably determine that its continued participation in the arrangement with a particular company would adversely affect the goodwill and reputation of SIR or its affiliates. In the event of any such termination, SIR will relinquish the supporter's contribution and return all unused funds. Upon expiration or termination, no further use of SIR's name may be made by the supporter without the written approval of SIR.
17. Oversight. SIR's Executive Council is responsible for establishing the principles and guidelines governing SIR's relationships with corporations. SIR's executive director is responsible for day-to-day oversight of all corporate arrangements.
Approved by SIR's Executive Council: November 2011; reviewed annually.
Please also refer to the SIR Foundation policy on corporate relationships.
James F. Benenati, MD, FSIR, on the need to empower all parties in the engine for IR innovation and growth.