Financial Conflict of Interest Policy

Process Owner

Senior Executive Human Resources

Purpose

To establish guidelines for avoiding apparent, potential and actual Financial Conflicts of Interest (FCOI) and guidelines for disclosure, review and management of conflicts of interest.

Definitions, Terms and Acronyms

Financial Conflict of Interest - A Financial Conflict of Interest (FCoI) is present when a significant financial interest affects, or could appear to affect, the professional judgment of a researcher, investigator, or employee in the course of their duties. For a researcher or investigator, the course of their duties would be designing, conducting, or reporting research.

Significant Financial Interest (SFI) - Financial interest of such magnitude and materiality that it would impeded objective decisions.

Immediate Family - Refers to any of the following familial relationships (whether genetic or legal): husband, wife, father, mother, son, daughter, brother, sister, grandmother, grandfather, grandson, granddaughter, aunt or uncle, niece or nephew.

Background

GovC is committed or operating without and Financial Conflicts of Interest with any employees, agents, subcontractors, or temporary employees. GovC is supports confidentiality and security in all research, sponsored programs, technology transfer and all other of its activities. Such activities shall be conducted in full compliance with this policy, and all federal and state laws pertaining to conflicts of interest.

Policy

Employees must not engage in any activity or practice that conflicts with the interests of the corporation or its customers, and must avoid actions or inaction's that create even the appearance of a conflict of interest (whether potential or actual). GovC has a responsibility to establish and maintain policies that promote objectivity in its dealings.

Disclosures shall be submitted in accordance with this policy and described procedures to the head of HR and/or Legal. FCOI that cannot be sufficiently reduced, mitigated, or eliminated may not be permitted and, as such, the proposed activity may need to be redesigned to reduce, mitigate, or eliminate the FCOI or shall not proceed, as determined by the Human Resources and Legal in collaboration with other persons/offices affected, as required to ensure organizational and individual compliance with applicable state and federal requirements.

Requirements

1. Employees shall not accept concurrent, full-time, part-time, or temporary employment in any organization that does business with GovC, is a supplier to GovC or is a competitor of GovC.

2. If a GovC employee or a member of their Immediate Family has a financial interest in a firm that does business with GovC or is a competitor of GovC, that employee shall:

(i) should promptly disclose the connection in accordance with GovC’s Standards of Ethics and Business Conduct; and

(ii) Shall not represent GovC in transactions with such a firm.

(iii) Ensure no business information is shared (offered or accepted) that could result in a competitive advantage for either company.

3. Employees shall not directly or indirectly hire, fire, discipline, promote, compensate or evaluate an Immediate Family member.

Responsibilities

All Employees

It is the responsibility of all employees to abide by the guidelines set forth in this Financial Conflict of Interest policy.

Hiring Managers

Hiring managers shall ensure new existing and new employees have been communicated the requirements of this policy and are in compliance with it.

The failure of an employee to abide by the guidelines set forth in this Financial Conflict of Interest policy may result in disciplinary action, up to and including dismissal.

Procedures and Guidance

Disclosures

Timing

SFI are required to be disclosed immediately to Human Resources and Legal.

Reviews

SFI reviews for potential FCOI shall be completed in advance of approval of the related Organizational agreement, contract or grant and before performance and in advance of any expenditures.

Training

FCOI training shall be required when employees, contractors, subcontractors or temporary employees are participating in programs that lends itself to FCOI.

Certification

Employee must certify there is no Financial Conflict of Interest.