Conflict of Interest

Conflict of Interest

Policy for Conflict of Interest due to Tobacco Industry Engagement

1. Purpose

The Narotam Sekhsaria Foundation (NSF) is committed to advancing public health and reducing tobacco-related harm in India and globally. In line with the WHO Framework Convention on Tobacco Control (FCTC), Article 5.3, national laws such as COTPA (2003) and PECA (2019) and the Code of conduct issued by the Ministry of Health and Welfare, NSF ensures that its funding, partnerships and operations remain independent of tobacco industry influence.

2. Scope

This policy applies to:

  • All grant applicants and grantees
  • Partner organizations and collaborators
  • Consultants, vendors, and contractors

3. Policy Statement

NSF will not fund, partner with, or support any organization or individual that:

  • Receives financial or in-kind support from the tobacco industry or its affiliates.
  • Has board members, senior staff, or decision-makers with current or recent roles in the tobacco industry.
  • Undertakes activities that promote or align with tobacco industry interests, directly or indirectly.

CSR funds, front groups, subsidiaries, trade associations, and entities lobbying for tobacco interests are included in the definition of “tobacco industry.”

4. Disclosure

  • Applicants/Partners must declare past or present funding, affiliations, or conflicts of interest through the Conflict of Interest Declaration Form.
  • All parties must promptly disclose any new or emerging conflict.

5. Due Diligence

NSF conducts background checks on applicants, partners and vendors to ensure independence from tobacco industry influence. Periodic compliance checks and documentation may be required.

6. Non-Compliance

Violation or failure to disclose conflicts may result in:

  • Rejection of applications
  • Termination of ongoing grants/partnerships
  • Blacklisting from future opportunities
  • Public disclosure

7. Past Industry Associations

  • Automatic Disqualification: If current funding, leadership ties, or activities align with the tobacco industry.
  • Conditional Consideration: If funding ceased ≥5 years ago, leadership is independent, and the organization has adopted a no-tobacco policy, subject to enhanced due diligence and possible conditions (e.g., cooling-off period, additional monitoring).