Conflict of Interest
Policy and Procedure: Corporate Compliance
Topic: Conflict of Interest
Purpose:
All employees and Board members of Birch Family Services (sometimes referred to as “Birch” or “the Agency”) have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy is established to ensure that services and business activities are conducted in an objective manner and are not motivated by desire for personal or financial gain.
Policy:
- Employees and Board members are required to disclose any actual or potential conflict of interest and seek guidance on how to handle the situation.
Conflict of Interest: Any situation in which financial or other personal considerations may compromise or appear to compromise (1) an employee or Board member’s business judgment; (2) delivery of services; or (3) ability for an employee to do his or her job. An actual or potential conflict of interest occurs when an employee or Board member is in a position to influence a decision that may result in a personal gain for that employee, Board member, or for a relative as a result of business dealings. For the purpose of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage. - Business dealings with outside entities should not result in unusual gain for those entities, Birch, Board member, or an employee. Unusual gain refers to gifts, bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both or that would reasonably be determined to influence the employer, employee, or both.
- The materials, products, designs, plans, ideas, and data are the property of the Agency and should never be given to an outside firm or individual except through normal channels with appropriate prior authorization. Any improper transfer of material or disclosure of information, even though it is not apparent that an employee has personally gained by such action, is prohibited.
Procedures:
- An employee or Board member with questions or concerns about potential conflicts of interest will promptly address the issue with appropriate management staff and/or the Compliance Officer. Management staff will consult with the Compliance Officer before responding to a concern or question about a potential conflict of interest.
- Actual or potential conflicts of interest must be disclosed to appropriate management personnel, human resources, or the Compliance Officer.
- Employees must disclose any potential conflicts of interest upon hire and when a potential conflict arises.
- Employees will complete a Conflict of Interest Disclosure Form (Appendix A to this Policy) to report any potential conflict of interest.
- The Compliance Officer will assure that members of management and the Board of Directors will complete a Conflict of Interest Disclosure Statement annually.
- Employees must seek guidance and approval from appropriate management personnel prior to pursuing any business or personal activity that may constitute a conflict of interest.
- Outside employment may not interfere with the employee’s ability to perform his or her job with Birch. In addition, Agency employees may not engage in any activities that may conflict with Birch or its clients.
- The Compliance Officer will investigate any violations of this policy.
