Charitable Conflicts of Interest

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ABSTRACT. This paper looks at conflicts of interestin the not-for-profit sector. It examines the natureof conflicts of interest and why they are of ethicalconcern, and then focuses on the way not-for-profitorganisations are especially prone to and vulnerableto conflict-of-interest scandals. Conflicts of interestcorrode trust; and stakeholder trust (particularlyfrom donors) is the lifeblood of most charities. Wefocus on some specific challenges faced by charitableorganisations providing funding for scientific (usuallymedical) research, and examine a case study involvingsuch an organisation. One of the principal problemsfor charities of this kind is that they often distributetheir funds within a relatively small research commu-nity (defined by the boundaries of a small region, likean American state or Spanish Autonomous region,or a small country), and it often proves difficult tofind high-level researchers within the jurisdiction toadjudicate impartially the research grants. We suggestand recommend options appropriate for our casestudy and for many other organisations in similarsituations.

KEY WORDS: business ethics, charities, conflict ofinterest, non-profits, organisational ethics, trust

In this article we discuss some special challengesthat conflicts of interest present for not-for-profitorganisations (NFPs). There are three reasons fordevoting attention to conflicts of interest inNFPs. First, because the NFP sector has beenneglected in the recent literature on conflicts ofinterest, which has focused almost exclusively onthe for-profit and governmental sectors. Second,NFPs find themselves especially prone to con-flicts of interest in part, ironically, because oftheir reliance on volunteers – people who aregenerally of exemplary good will. And third, itmay well be that the consequences of an actualor perceived conflict of interest are much moreserious for many NFPs than they are othertypes of organisation. All the world loves tohate the hypocrite; and when people appearto be enriching themselves behind the veilof self-sacrifice and charity, the righteousindignation flows. This can happen even whenthere is no actual hypocrisy, corruption, or abuseof trust, but only the appearance thereof. Lossof public faith in the organisation, whetherjustified or not, could be devastating. Where aconflict-of-interest “flu” in a for-profit businessmight result in a minor lawsuit, or in someonebeing sacked, it could be life-threatening for anNFP.

Of course, NFPs come in all shapes and sizes– from wine-tasting clubs to local charities tomajor international organisations like Greenpeaceand Amnesty International. We will make noattempt to canvass all of the special kinds ofactivities that could give rise to conflicts ofinterest in all of these different kinds of organi-sations. Instead we will focus on a common kindof NFP that has been neglected in the business-ethics and governance literature: charities that

Charitable Conflicts of Interest

Journal of Business Ethics

39: 67–74, 2002.© 2002 Kluwer Academic Publishers. Printed in the Netherlands.

Chris MacDonald teaches for Dalhousie University’sPhilosophy Department. He has recent or forthcomingpapers in the Journal of Social Philosophy,Cambridge Quarterly of Healthcare Ethics, and theFebruary 2002 issue of Journal of Business Ethics.

Michael MacDonald is the Maurice Young Chair in Applied Ethics at the University of British Columbia (UBC). A former President of the CanadianPhilosophical Association, he has published on a widearray of topics in applied ethics.

Wayne Norman is Chair in Business Ethics at UBC andVisiting Scholar at the Center for Social Innovation,Stanford University. His MBA team won the BlizzardAward in 2001 for best collaborative teaching inCanadian higher education.

Chris MacDonaldMichael McDonald

Wayne Norman

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raise funds to sponsor scientific research forspecific causes.1 These charities are typicallyorganised around health issues (such as cancer, orAlzheimer’s disease, or the health of specificorgans like the kidneys). And they typically havemandates to promote public awareness as well asresearch. In many large countries it is also typicalthat charities like these are operated on a regionalbasis. So although there may be a Blogg’s DiseaseResearch Foundation of America – to take animaginary example – there may also be regionaland state chapters of the Foundation that operatelargely independently. As we shall see, when itcomes to conflicts of interest in research-grantinginstitutions, size matters. In relatively small com-munities (such as many states in the U.S.A. orprovinces in Canada), as well as in many rela-tively small countries, it is a challenge to awardgrants without risking conflicts of interest. Thesmaller the community, the smaller the commu-nity of researchers studying the disease (or rangeof diseases) in question; and the smaller theresearch community, the harder it will be to finddisinterested referees and committee members toset research-funding policy and to award andmonitor grants.

Before turning to discuss in more detail theissues facing NFPs, it is worth surveying theconcept of a conflict of interest and the moralissues it raises.

Conflicts of interest

We can define a conflict of interest as a situationin which a person has a

private or personal interestsufficient to appear to influence the objective exerciseof his or her official duties as, say, a public official,an employee, or a professional.2

There are three key elements in this definition.First, there is a private or personal interest. Oftenthis is a financial interest, but it could also beanother sort of interest, say, to provide a specialadvantage to a spouse or child or colleague. Therelevant interest can be as abstract as the vast arrayof desires that motivate us. For example, a pur-chasing agent may have an interest (not shared byher company) in boycotting the products of afirm she considers to be unethical.

There is usually nothing wrong with havingor even pursuing most private or personal inter-ests in one’s private life. The problem comeswhen this private interest conflicts with thesecond feature of the definition, an “officialduty”. As a professional, an employee, or even avolunteer, you take on certain official responsi-bilities, through which you acquire obligationsto clients, employers, or others (That is, youtake on a role in the significant sense discussedby Davis (1982, p. 22)). These obligations areusually supposed to trump private or personalinterests.3

The third relevant element of this definitionis what brings the personal interest and theorganisation’s interest into conflict: namely thepersonal interest influencing or possibly appearingto influence the insider’s judgment or motivationto fulfil his or her organisational obligations.This is the most morally peculiar feature ofconflicts of interest. The person in a conflict-of-interest situation need not actually make a biasedjudgment. In fact, this person could resolutelyresist the tug of her personal interest and doexactly what her employer or profession expectsof her.4 In such as case, she certainly avoidscorruption (which requires a personal benefitin violation of one’s official duties), but shemay nevertheless cause harm to her organisationor profession. If beauty is in the eye of thebeholder, then so too, in effect, is a conflict ofinterest.

Conflicts of interest are morally harmful inthat they corrode trust. Trust is of enormousvalue for any organisation or cooperative rela-tionship.5 It is a large factor in what has becomerecognised as “social capital”.6 When peoplein a cooperative relationship are trustworthy andtrusted, there are benefits on all sides, not leastfrom saving the costs of monitoring, auditing,enforcing rules for every miniscule transaction.7

Why is trust especially valuable for NFPs?Mainly because of the kinds of relationships theyhave with their principal stakeholders – especiallywith donors and volunteers. In for-profitdealings, parties may be willing to take greaterrisks because of the potential material rewards.But for donors and volunteers, the feeling thatthey are doing good is often the only reward.8

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And if donors even suspect that some individualwithin the charity may be personally benefitingfrom the donation at the expense of the “cause”to which the money was donated, then they arelikely to seek other causes and organisations tosupport. If publicity about a possible conflict ofinterest within an NFP is at all widespreaddonations could evaporate overnight. For manycharities, this is the only significant source ofrevenue, their lifeblood. This fear, and the roleof trust in allaying it, is the reason that Boardsand managers of charities must be ever vigilantabout conflicts of interest.

Charities, especially relatively small andlocalised charities, are not only especially vul-nerable to conflict of interest scandals; they faceparticularly difficult challenges in trying toprevent them. To illustrate some of these chal-lenges let us look at a hypothetical, but in manyways typical, example of a regionally basedresearch-funding charity. We hope that bylooking at one specific type of NFP we can showsome ways of identifying problems, and consid-ering solutions, that would be relevant to othersorts of NFPs as well.

Case study: potential conflicts of interestat “NIRF”

The hypothetical organisation we will describe isbased on a real one that we have studied in somedetail, with extensive interviews on-site and withcertain stakeholders, as well as through a reviewof their rules and documentation. For obviousreasons we will disguise various bits of partic-ular information about the organisation –including its name and location. Our aim is notto praise or criticise practices within this partic-ular NFP, but rather to use a fairly concreteexample to illustrate a range of issues and somepractical ways of working through them.

NIRF-Cascadia is the local branch, operatingin the (fictional) state of Cascadia, of theAmerican national Nasty Illness ResearchFoundation. This foundation is dedicated tofinding treatments for, and ways of preventing, arather common “nasty illness” that typicallyaffects at least some members of most extended

families. NIRF-Cascadia raises most of its oper-ating funds within Cascadia, a medium-sized statewith about five million inhabitants; and it trans-fers about 15% of the funds it raises to thenational organisation, primarily to support thehead-office expenses as well as national publicitycampaigns, lobbying and the like. Its annualbudget fluctuates around ten million dollars, withmore than half going to fund research withinCascadia itself – mostly to scientists in the onlytwo medical schools in the state. Funds are raisedfrom some very large donations and endowmentsby philanthropists, as well as from thousands ofvery small donations raised primarily from apopular campaign each autumn. By comparativestandards, it is quite a successful charity, and theresearch it has funded over the past three decadeshas resulted in some significant advances in thetreatment and prevention of this very complexillness.

Nevertheless, both the Executive Director andthe President of NIRF-Cascadia (hereafter,NIRF) have become concerned about gover-nance issues in general, and conflicts of interestin particular. As a professionally managed organ-isation, NIRF has long had a conflict-of-interestpolicy on the books. It has also drawn the policyto the attention of new employees, boardmembers and volunteers on research committees.There can be no doubt that the policy was drawnup by lawyers. The heart of the policy reads asfollows:

A volunteer or staff member who is a party in anycapacity or has an interest in a party to a materialcontract or proposed material contract with NIRFmust disclose in writing, or request to have entriesin the minutes of appropriate meetings in the caseof members of the Board or Research Committees,the nature and extent of any such personal interestin the transaction or with parties to the transac-tion. . . .

Sufficient declaration of interest by a volunteeror staff member is a general notice to the direc-tors or appropriate managers, and copied in allcases to the Chairman of the Board, declaring thevolunteer or staff member is a director or officerof, or has a material interest in, a company orperson and is to be regarded as interested in anycontract made with that company or person.

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The next clause of the policy goes on to explainhow NIRF reserves the right to set aside anycontract signed by a conflicted officer of theFoundation. The policy also sets out responsi-bilities for volunteer directors, the ExecutiveDirector, and the Chairman of the Board forreporting and deciding whether reported con-flicts of interest exist, and if so, what shouldbe done about them. It also calls for an annualdeclaration of potential conflicts by Boardmembers.

Despite having what seemed to be a verythorough conflict-of-interest policy on thebooks, the Executive Director and Presidentremained concerned for a number of reasons:

• They were not sure how well understoodthe policy was throughout the organisation.

• The policy said a lot about disclosing poten-tial conflicts of interest, but relatively littleabout what should be done once they weredeclared.

• There are a number of “relationships” thatwere properly declared, but allowed topersist.

• In particular, there seem to be unavoidableconflicts of interest for members of theresearch community that volunteer for theorganisation but also apply for and receivedresearch grants.

Policies and practices

We will turn now to the kinds of policies andpractices organisations like NIRF can put intoplace to deal with conflicts of interest. We shallmake some general comments about the first twoconcerns raised by the heads of NIRF, althoughthe ultimate solutions will be very specific to thatorganisation. We will concentrate on the thirdand fourth concerns, which are likely to beproblems for many or most charities (in the caseof the third), and most charities that fundresearch within a relatively “closed” researchcommunity (in the case of the fourth).

An American lawyer, Jennifer ChandlerHauge, provides a useful outline of what a com-prehensive COI policy should include.9

1. A definition of what constitutes a conflictof interest.

2. A duty of disclosure.3. Procedures to determine if a conflict of

interest truly exists.4. Policies and procedures to follow when

there is a genuine conflict of interest.5. Detailed protocols for record keeping about

possible conflicts of interest and how theyare handled.

6. A plan for communication and for securingcommitment.

The first, second and sixth of these points speakdirectly to first-mentioned concern by the headsof NIRF, namely, that they were uncertain howwell understood the conflict-of-interest policy iswithin the organisation. Their concern hereseems quite legitimate. The wording of the actualpolicy gives some indication of how poorlyunderstood it is likely to be, but also about howdifficult it is likely to be to communicate thepolicy and expect employees and volunteers to“buy in.” Again, it seems clearly to have beencrafted – which is not to say that it has beendrafted clearly! – by lawyers. (How many non-lawyers understand what a “material contract”is?) And while presenting such a policy toemployees or volunteers on their first day on thejob may “cover” the organisation in the eventof a future conflict-of-interest violation, thisshould hardly be thought to be the primary pointof sound conflict-of-interest management. As wenoted, the main worry for an NFP (unlike atypical company in the private sector) is not thata conflicted employee may sign a contract thathigher management would like to be able to setaside. It is that news of a conflict of interest willleak out and corrode the trust and confidenceof such key stakeholders as the general public anddonors.10

As a model of a thorough policy that coversall of the points on Hauge’s list, above, werecommend that NFPs like NIRF look at theconflict-of-interest policy of the American HeartAssociation. Particular features of the AHA’spolicy that warrant commendation are its inclu-sion of a lengthy “definition” which managesto give numerous specific examples, and its

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thorough five-point disclosure questionnaire thatvolunteers and employees are required to fill outperiodically.11

In the space that remains we would like tolook in more detail at two kinds of conflicts ofinterest that are especially troubling for NFPs,in part because they are often persistent and eveninherent to the operations of these organisations.

Specialists on the Board

The first such problem concerns the role of“specialists” on the Board. For our purpose it isworth distinguishing two kinds of specialists:those who have professional expertise in, forexample, banking, law, accounting, or marketing;and those who have scientific expertise in thearea of direct concern to the research-grantingNFP. Due to considerations of space, we willdiscuss only the situation of the latter group.

Charities like NIRF spend almost all of theirfunds (apart from operating and marketingexpenses) supporting research. Their fundraisingcampaigns emphasise their role in finding curesto “Nasty Illness”. It is inconceivable that theBoard of such an organisation could make effec-tive strategic decisions without significant inputfrom researchers in the fields receiving grants;and most likely it would be thought essential tohave such researchers on the Board itself. But thepresence of researchers on the Board creates somepotentially explosive conflict-of-interest situa-tions. After all, decisions about the awarding ofgrants necessarily involve distributing large sumsof money to specific individuals and organisa-tions. That some of this money could be goingstraight to members of the Board, their labora-tories or departments, even their colleagues,friends and former students, is very worryingindeed. And yet this is actually the norm fororganisations like NIRF. Why does this happen,and what can be done about it?

It is worth distinguishing two kinds of con-flicts involving scientists on charity boards. Thereis the kind of case just alluded to, where indi-viduals on the Board have personal or profes-sional interests in who gets funding (even in caseswhere the Board itself does not make the funding

decisions). We will deal with this issue in thenext section where we look at conflicts of interestin grant-awarding more generally. The secondconflict involving scientists at the Board level issubtler. For most of the particular kinds of illnessthat are the raison d’être of charities – such ascancer, AIDS, heart and stroke, diabetes, etc. –there are a great many research fields involvedin looking for a cure. Specialists from almostevery department in a medical school might beworking on various aspects of a disease – not tomention psychologists, ethicists, demographers,occupational therapists, and others. This raisesthe problem that researchers on the Board of acharity will have an interest, or even just anhonest bias, in steering the organisation’s strategicfunding priorities in the direction of theirparticular research field. There is no doubt, atany rate, that this would be the perception ofresearchers in fields that seem to be under-fundedby the organisation when they see the better-funded fields represented on the Board.

There is no simple, general solution to thisneglected form of conflict of interest. The firststep for a board is to become aware that this isa problem. Among the possible solutions arethese.

• Create a subcommittee of the Board, or aseparate committee reporting to the Board,that seeks the broadest and most inclusiverepresentation from the research fields.

• If this is too unwieldy, the Board could(with outside consultation) identify therelevant fields, and have a policy of rotatingspecialists from these various fields in andout of Board positions on an annual orbiannual basis.

• In either case, the Board should periodicallycommission an outside review of its opera-tions and strategic funding priorities byrespected researchers from well away fromits local research base (ideally from abroad).

Again, the aim here is to enable the Board todefend the organisation against any accusationthat its funding decisions are made on groundsirrelevant to the mission of the organisation.

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Conflicts of interest in awarding grants

And this brings us finally to the conflict-of-interest problem of greatest concern to the headsof NFPs like NIRF: how to avoid conflicts ofinterest in the awarding of research grants. Thefundamental problem here is the size of theresearch community being “served” by NIRF.Here again are the salient facts: virtually all ofNIRF’s research funding is distributed within thestate of Cascadia (it feels that it is able to raisesignificantly more money by pledging to supportlocal researchers and clinicians); there are onlytwo major research medical schools within thestate; the number of researchers applying forthese funds is small – we are told that morethan half of them routinely win NIRF grants.“Everyone knows everyone,” is what we arerepeatedly told about this research community. Ifwe consider in addition that grants typically runfor three years, and are evaluated for a “morethan rubber-stamping” approval every year, andthat each project often has several names attachedto it, we begin to see how difficult it will be tofind non-conflicted, top-level “nasty illness”researchers in Cascadia to evaluate grant proposalsand second- and third-year renewals.

Like most important research-funding bodies,NIRF has long made it mandatory for conflictedmembers of research committees to absent them-selves from the room while an application withwhich they have a conflict is being discussed.There is no denying that this practice must bemaintained. The question is whether it is suffi-cient to protect NIRF against accusations ofconflicts of interest; and we believe it is not.This strategy may well be sufficient in manyother contexts, in particular for large grantingagencies (like the National Institutes of Health inthe U.S.A., or the British Medical ResearchCouncil). Agencies of this size can afford theluxury of relatively large grant-adjudication com-mittees, and any given member of the committeemay not have to absent himself or herself formore than one or two applications per day ofdeliberations, even using the very broadestcriteria for a conflict (e.g., being conflicted if theapplicant comes from your university). Theproblem for organisations like NIRF is that the

absenting strategy creates the opportunity for“mutual back-scratching.” Person A leaves theroom while B and C decide about A’s grant (orthe grant by the person with whom A has aconflict of interest); then B leaves the room, andA and C decide, and so on. An unbiased observerwould query the potential for conflicts of interestflourishing in this environment.

Organisations like NIRF have to look formore creative practices to supplement the use ofabsenting. Here are a few examples:

A. Adding an Outside Expert as Chair of theCommittee. This person should be ofunblemished integrity with a sufficientbreadth of experience in the field. It couldideally be a senior researcher from a distantstate or country, or perhaps even a recentlyretired researcher from the local commu-nity. The Chair’s primary duty should beto oversee the integrity and impartiality ofthe Committee, and he or she shouldreport directly to the Board of theFoundation.

B. Adding Other Kinds of Members to theCommittee. The Committee could beexpanded to include at least one laymember, as well as members from otherresearch fields close to those funded by theparticular charity in question.

C. Recruiting Entire Committees from Outside theState. This is a radical solution that isthought not to be feasible by someresearchers we interviewed. Committeemembers from out-of-state (or fromabroad) could either be paid an hon-ourarium for their services, or a Cascadiancommittee could, so to speak, be swappedwith a committee from another state witha similarly sized branch of NIRF. (A com-mittee made up of Cascadian researcherscould evaluate the applications for NIRFfunding in Kansas; and the committee inKansas could do the same for NIRF appli-cations in Cascadia.) As far as we knowthis solution has never been tried in NFPslike NIRF that leave a significant degreeof fundraising and research-grantingautonomy to their regional chapters. But

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our interviews with researchers did notgive us any reason to think it would beunfeasible.

D. Research-Funding Decisions Could beCentralised. Research-funding applicationscould be adjudicated by the nationalorganisation rather than by the state orregional chapters.12 In fact, this is alreadydone, in part, within the national NIRForganisation. A national committee ranksall applications. But the funding decisionsare still made locally, and some discretionis needed because (a) the rankings are donewithin the various specialised fields, andthe local organisation has to decide howto allocate its funding across fields; (b)there are decisions to be made about howmuch money to award to particularprojects, given the total available in thelocal organisation; and (c) the local organ-isation may legitimately want to set its ownresearch priorities, given local needs andfacilities.

There are of course other potential solutions.The main point here is recognising the inade-quacy for smaller organisations or research com-munities of the standard “absenting” strategyused by large funding bodies. Organisations likeNIRF probably have no more obvious a“whistleblower” to fear than the disgruntledresearcher looking for reasons to explain why henever seems to get a NIRF grant.

Conclusion

Obviously, we have not dealt with all, or evenmost, of the potential conflicts of interest in not-for-profit sector. Our purpose here has been two-fold. First, to give a basic sense of the rootconcern about conflicts of interest in a way thatwill hopefully facilitate clear thinking about whatkinds of conflicts organisations should be worriedabout, and why they should be worried.Perceptions of conflicts of interest erode stake-holder trust, even when the individual at thecentre of the perceived conflict is in fact ofunflinching integrity. And trust is the lifeblood

of most not-for-profit organisations. This pointsto our second purpose: the question of howto think through policy solutions to obviateconflicts of interest. There is rarely a one-size-fits-all solution here. The main purpose of anyconflict-of-interest policy is to safeguard stake-holder trust and confidence. For typical NFPs,this necessarily requires compromises becausethat trust and confidence in charities also dependson the ability of the organisation to direct mostof it resources to its primary mission: moneyspent to assure the most unassailable conflict-of-interest policy (say, flying in a team of interna-tionally recognised researchers to review localgrant applications) cannot be spent on, say, cancerresearch. We have tried to illustrate ways an NFPcan build on and protect the stock of trust italready has with its main stakeholders throughmeasures they would likely find both reasonableand reassuring.

Notes

1 See O’Connell (1996), and Fram and Withers(1999).2 This definition consolidates insights from a vigorousphilosophical debate initiated by Davis (1982).Other notable contributions include Luebke (1987),Boatright (1993) and Gunz and McCutcheon (1991).3 Extraordinary circumstances include situations inwhich an employee is being asked to help the organ-isation do or conceal an illegal or unethical activity.Such circumstances give rise to the issue of whistle-blowing. For a discussion of the limits of loyal agency,see Michalos (1999) and Poff (1999).4 Lemmens and Singer (1998) note that “having aconflict of interest is an objective situation and doesnot depend on underlying motives”. 5 See MacDonald (1998) and Lemmens and Singer(1998).6 There is a burgeoning literature on trust and socialcapital. See Cohen and Prusak (2001).7 Frank (1999, pp. 164–168).8 Frank (1999, p. 168) actually measures the valueemployees attach to working for socially responsiblefirms.9 The web site from which we drew Hauge’sthoughts on conflicts of interest seems no longer tobe in operation.10 In the words of one expert, Brian Rines, “The

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community has to know you mean business – it’s theirmoney you’re spending” (quoted in Larson (2001),p. 8).11 This policy is not available on the AHA’s web site,www.americanheart.org; but we understand that theywill make the policy available upon request.12 This solution will usually not be available toresearch NFPs within small states in Europe. Thereare few transnational, Europe-wide, or even EU-wide,NFPs of this sort. It is possible, however, that theparallel organisations in several small countries (say,AIDS-research charities) could create a multinationalcommittee to evaluate and rank grant applications,with each country’s organisation then deciding howto allocate its funding to the applicants whose projectswere deemed worthy.

References

Boatright, J. R.: 1993, ‘Conflict of Interest: AResponse to Michael Davis’, Business & ProfessionalEthics Journal 12(4), 43–46.

Cohen, D. and L. Prusak: 2001, In Good Company:How Social Capital Makes Organisations Work(Harvard Business School Press, Cambridge, MA).

Davis, M.: 1982, ‘Conflict of Interest’, Business &Professional Ethics Journal 1(4), 17–27.

Davis, M.: 1993, ‘Conflict of Interest Revisited’,Business & Professional Ethics Journal 12(4), 21–41.

Fram, E. H. and J. Withers: 1999, ‘Conflict of Interestin the Board Room?’ Nonprofit World 17(2), 19–21.

Frank, R.: 1996, ‘Can Socially Responsible FirmsSurvive in a Competitive Environment’, in DavidMessick and Ann Tenbrunsel (eds.), Codes ofConduct: Behavioral Research into Business Ethics(Russell Sage Foundation), pp. 86–103.

Gunz, S. and J. McCutcheon: 1991, ‘SomeUnresolved Ethical Issues in Auditing’, Journal ofBusiness Ethics 10, 777–785.

Lemmens, T. and P. Singer: 1998, ‘Conflict of

Interest in Research, Education and PatientCare’, Canadian Medical Association Journal 159,960–965.

Luebke, N. R.: 1987, ‘Conflict of Interest as a MoralCategory’, Business & Professional Ethics Journal 6(1),66–81.

MacDonald, C.: 1998, ‘Trust in the Market Place: AnExploratory Computer Simulation’, Business &Professional Ethics Journal 16(1–3), 225–238.

McDowell, B.: 1990, ‘The Professional’s Dilemma:Choosing Between Service and Success’, Business& Professional Ethics Journal 9(1&2), 35–52.

Michalos, A.: 1999, ‘The Loyal Agent’s Argument’,in D. C. Poff and W. J. Waluchow (eds.), BusinessEthics in Canada, 3rd edn. (Prentice Hall,Scarborough, ON).

O’Connell, L. J.: 1996, ‘Recognizing Conflict ofInterest’, Healthcare Executive (May/June), 48–49.

Poff, D.: 1999, ‘The Loyal Agent’s ArgumentRevisited’, in D. C. Poff and W. J. Waluchow(eds.), Business Ethics in Canada, 3rd edn. (PrenticeHall, Scarborough, ON).

Chris MacDonaldDepartment of Philosophy,

Dalhousie University,Canada

Michael McDonaldCentre for Applied Ethics,

University of British Columbia,Canada

Wayne NormanCentre for Applied Ethics,

University of British Columbia,Vancouver, BC,

Canada V6T 1Z2E-mail: [email protected]

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