Conflict of Interest Policy

Subscriber Content
Preview Image
Image
screenshot of the first page of Conflict of Interest Policy

Guidelines for Identifying and Managing Conflicts of Interest.

This Conflict of Interest Policy provides a structured approach for organizations to identify, address and manage potential conflicts of interest among all employees. Sample 1 is tailored for senior leadership and governance, while Sample 2 is broader, encompassing all employees and emphasizing operational protocols. Both samples underscore the importance of disclosure, transparency, and adherence to ethical practices to safeguard the organization's integrity and reputation.

Sample 1 outlines the responsibilities of senior leadership, requiring annual disclosures of financial interests and corporate opportunities to maintain transparency. It defines key terms such as "Interested Person" and "Financial Interest," establishing procedures for disclosing conflicts and determining appropriate actions through independent committees or executive management.

Sample 2 extends these principles to all employees, emphasizing the importance of immediate disclosure of any actual or perceived conflicts to the General Manager. This sample details the steps for reporting, investigating and resolving conflicts, along with the consequences of non-compliance, which may include disciplinary actions. This policy aims to uphold ethical standards and ensure that all organizational members act in the best interests of the company, fostering a culture of integrity and accountability throughout the organization.

Sample procedures include:

  • The executive management committee should report, in writing, to the independent committee each determination it makes regarding a potential corporate opportunity.
  • Each member of the board should annually disclose in writing to the independent committee all of all his or her board of directors, advisory board or equivalent positions in other companies.
  • The General Manager should investigate the disclosure and seek legal counsel, if appropriate, regarding what steps should be taken as a result of the conflict of interest.
  • A copy of this policy should be provided to each employee on his or her first day of employment with the company and periodically thereafter as deemed necessary by the General Manager.