Conflict of Interest and Cooling-off Period Guidelines

The Global Hypergrowth Project (GHP) guidelines on Conflict of Interest and an investment Cooling-off Period are as follows:

Conflict of Interest

Panel Members are bound to declare any real or perceived conflicts of interest as a provision of the Conflict of Interest & Confidentiality (COI&C) agreement that must be signed prior to participation on the GHP Selection Panel. The agreement also stipulates that any confidential information disclosed to panel members should not be used for any purpose other than their selection panel deliberations. ISED will retain all agreements as official records. The program website will include an overview of how conflict of interest is being managed as well as a clean version of the COI&C agreement to demonstrate to Canadians the processes undertaken to prevent real or perceived conflicts of interest.

Once the Selection Panel review commences in the Fall, Selection Panel members are required to declare any potential conflicts prior to assessment meetings. The GHP Selection Panel Secretariat will undertake the following procedures in order to effectively capture and manage any conflicts that arise:

  • Selection Panel members will receive requests at key intervals during the assessment process to declare any real or perceived potential conflicts. These include:
    • During the Level 1 Assessment when successful applicants are placed into the Longlist (top 20 for consideration by the Panel)
    • Once the Longlist (top 20) has been established
    • When receiving dossiers for the top 20 applicants
    • When receiving the invite for each company assessment meeting.
  • Previously declared conflicts will be announced at the start of each company assessment meeting and Selection Panel members will be asked one more time to declare conflicts before the company is discussed.
  • Selection Panel Co-chairs will manage all potential conflicts at their discretion and seek recusals from conflicted members at the appropriate time.
  • Records of discussion will record decisions on conflicts of interest, including the identification of reclused individuals

Cooling-off Period

In order to minimize the perception that Selection Panel Members might benefit from privileged information, the COI&C also includes cooling-off provisions.

  • Panel members are to refrain from personally investing in companies on the Selection Longlist (top 20) until 6-months after the date company names are announced.
    • Organizations affiliated with Panel members are free to take an interest or invest in a firm being reviewed by the Selection Panel provided that the affiliated organization has established an ethical wall between itself and the panelist. The COI&C agreement also sets some minimum standards for that ethical wall including eschewing discussion of any matters related to firms on the Selection Longlist.
  • The period of 6 months has been chosen by the department in order to:
    • Protect the integrity of the Selection Panel deliberations.
    • Ensure sufficient time has elapsed from the Panel’s recommendation to allow for the government’s implementation of the GHP effort.
    • Minimize the perception of Panel members investing based on insider information.
  • The start date of the Cooling-off Period is the date that the names of the GHP firms are publicly announced.