CONFLICT OF INTEREST
Policy Statement
It is the policy of [PROVIDER] to provide guidance and establish a procedure for the disclosure of potential conflicts of interest. Each employee is encouraged to act objectively when carrying out their duties as an employee of [PROVIDER] to include avoiding conflicts of interest.
Suggested Elements
Providers may wish to include the following suggested elements as part of their corporate compliance policy.
- Employees of [PROVIDER] may not work for, consult with, or have an independent business relationship with any of [PROVIDER’s] service providers, vendors, competitors, or third party payers. Employees may not invest in any payer, provider, supplier, or competitor, except through mutual funds or minority holdings of publicly traded securities.
- Employees should not have other employment or business interest if:
- The employee appears to represent [PROVIDER]
- The employee provides goods or services similar to those [PROVIDER] provides or is considering, or if.
- The other job interferes with the everyday duties as an employee of [PROVIDER]
- The employee should not use [PROVIDER] assets for personal benefit or personal business purposes. Employee should not have business dealings in products or real estate if the value may be affected by [PROVIDER] business. Employees may not disclose or use any confidential information, such as financial data, payer information, computer programs, and customer information, for their own personal and business purposes.
- Employees considering a second job, a consulting engagement, or healthcare-related investment, should review their plans with their immediate supervisor or the Compliance Officer. Approval in advance is required before beginning such a task.
CONFLICT OF INTEREST FOR DIRECTORS, OFFICERS, AND SENIOR MANAGEMENT
Policy Statement
It is the policy of [PROVIDER] to provide guidance and establish a procedure for the disclosure of potential conflicts of interest.
Suggested Elements
Providers may wish to include the following suggested elements as part of their corporate compliance policy.
- Whenever a director, officer or member of senior management has a personal interest in another party that has or may have business dealings with [PROVIDER], he or she should disclose that interest to the corporate secretary and refrain from participation in [PROVIDER] business decisions regarding that party.
- Whenever a director, officer or member of senior management has a personal interest in another party that has received or may receive a charitable contribution from [PROVIDER], he or she should disclose that interest to the corporate secretary and should seek permission from the corporate secretary before engaging in any discussions with [PROVIDER] concerning charitable contributions to that party.
- If a director, officer or associate is in a position where access to [PROVIDER’s] proprietary information may materially influence his or her decisions in another party engaged in business or competition with [PROVIDER] he or shall decline that information. Proprietary information includes financial, marketing, customer, pricing, medical management, or operations information and strategic plans and initiatives which are important to [PROVIDER] or any of its affiliated organizations.
- If a director, officer or employee is in a position where access to [PROVIDER’s] proprietary information may materially influence his or her personal financial or investment decisions, he or she should decline that information.
- Directors, officers and members of senior management should complete an annual statement, in a form prescribed by the company, disclosing financial, personal and other interests and relationships that may present a conflict of interest. Any change to the information set forth in the annual statement should be disclosed to the corporate secretary as soon as reasonably practical.