CONFLICT OF INTEREST

CONFLICT OF INTEREST

PURPOSE

Employer is committed to ensuring its employees avoid possibleconflict of interest situations by performing their duties in a professional and moralmanner. The goals are to prevent clients from being taken advantage of, to reducemanagement risks, to manage human resources, to deliver services effectively andefficiently and to prevent actual or perceived conflict of interest.

POLICY

Persons employed are responsible to their clients and co-workers to perform their duties at all times in a professional and ethical manner,without the intention of obtaining direct or indirect conflict of interest.

DEFINITIONS

1. Conflict of Interest

A person has a conflict of interest when he/she:

a. is in a position of trust which requires him/her to exercise judgment on behalf of others (people, institutions, etc.); and/or

b. has interests or obligations of the sort that might interfere with the exercise of his/her judgment; and/or,

c. is morally required to either avoid or openly acknowledge.

PROCEDURES

1. Clients shall be advised of their rights to be free from conflict of interest behaviors and conducts which take advantage of them and/or their situations.

2. Employees shall not do anything that could result in a conflict of interest for the Agency such as buying and selling.

3. Employees shall be advised that the following are some of the situations that may be considered as conflict of interest:

a. taking advantage of the professional relationship with a client, which results in personal gain for the employee and/or their family/friends;

b. entering into an employment relationship with another service provider which infringes on the employment relationship with this agency unless that relationship has been sanctioned by the Agency.

c. agreeing to provide service to any client where there is a personal/familial relationship, unless such a relationship has been disclosed to the Agency and has been reviewed and authorized.

4. Employees are to be provided with information on how to report potential/actual conflicts of interest.

5. Employees may not accept gifts, money, discounts or favors including a benefit to family members, friends or business associates for doing work that the company pays them to do.

6. Employees may not use, or permit the use of the Company’s property, facilities equipment, supplies or other resources for activities not associated with their work without authorization first from the Company.

7. Employees may not disclose confidential or privileged information for any purpose about the Company, co-workers, clients/families, or use confidential information to advance personal or others' interests

8. Employees shall advise the Manager/Administrator or Supervisor, in writing, of all other employment and possible conflict of interest situations.

GUIDELINES

1. A process shall be developed for all aspects of the conflict of interest policy including:

a. providing orientation to new staff of facts and examples and through verbalization of examples and distribution of written material;

b. advising clients of their rights to ethical and quality service;

c. advising management of potential conflict of interest situations;

d. documenting conflict of interest occurrences;

e. investigating procedures carried out by management and/or community resources;

f. providing detailed instructions for employees and clients/families for reporting potential conflict of interest situations;

g. disciplining staff, when indicated; and,

h. reporting conflict of interest involving regulated health providers to professional colleges or other appropriate organizations, when appropriate.

2. Education shall be given to all employees at orientation and via regular staff training and development sessions on conflict of interest

3. A record of training shall be kept for all employees and shall include:

a. dates when training was given;

b. summary on what training was given;

c. names and credentials of person(s) providing the training; and,

d. names and positions of people attending the training sessions. Records are to be maintained for 3 years from the date of training.

CROSS-POLICY REFERENCES

1. Disciplinary Action

REFERENCES

1. Department of Health and Human Services

2. National Science Foundation

3. Public Health Service

DUTY TO DISCLOSE

Each Staff Member has an obligation to disclose promptly, fully and in good faith a Financial Interest as well as any material activities or interests which involve obligations which compete with or are in conflict with the interests of your employer or potentially impact the safety or quality of care, treatment or services to its patients.

Disclosure actions will follow the processes described herein and in the related Conflict of Interest policies.

In the event any Staff Member identifies a potential Financial Interest or other Conflict of Interest as described in this Policy, it should immediately be disclosed in writing or electronic communication to his or her Manager. If the Manager believes there is a possibility of a Conflict of Interest he/she shall prepare a full written disclosure of all relevant facts regarding the Conflict of Interest

Conflict of Interest Disclosure Form

A potential or actual conflict of interest exists when commitments and obligations are likely to be compromised by the employees other material interests, or relationships (especially economic), particularly if those interests or commitments are not disclosed.

This conflict of Interest Form should indicate whether the employees have an economic interest in, or acts as an officer or a director of, any outside entity whose financial interests would reasonably appear to be affected by the addition. The employees should also disclose any personal, business, or volunteer affiliations that may be given rise to a real or apparent conflict of interest. Relevant Federally and organizationally established regulations and guidelines in financial conflicts must be abided by.




Please describe below any relationships, transactions, positions you hold (volunteer or otherwise), or circumstances that you believe could contribute to a conflict of interest:

I have no conflict of interest to report.

I have the following conflict of interest to report (please specify other non-profit And for-profit boards you (and your spouse) sit on, any for-profit businesses for which you or an immediate family member are an officer or director, or a majority shareholder, and the name of your employer and any businesses you or a family member own:



I hereby certify that the information set forth above is true and complete to the best of my knowledge.