Conflict of Interest Policy

1. Purpose

1.1This policy protects the institution's interests when it considers a transaction or arrangement that might benefit the private interest of a director, officer or member, and helps the institution comply with the federal and state law that applies to charitable organizations.

2. Who it covers

2.1It applies to directors, officers, employees, and members who contribute to research, advise on policy, or take part in grant decisions (together, 'covered persons').

3. What counts as a conflict

3.1A covered person has a conflict of interest where they, a family member, or an organization in which they have a financial or governing interest:

• Stands to gain financially from a transaction, grant or arrangement with the institution
• Has a financial interest in an entity whose products, markets or regulation are the subject of research they are contributing to
• Receives compensation or gifts from a party seeking something from the institution
• Holds a role that would divide their loyalty in a decision the institution is making

4. Disclosure

4.1A covered person must disclose any actual or potential conflict, in writing, to the Executive Director or, for directors and officers, to the Chairman, as soon as they become aware of it and before the matter is decided. Directors and officers also complete an annual disclosure statement.

5. Procedure

• The interested person may present information but leaves the discussion and does not vote
• The disinterested decision makers determine whether a conflict exists
• Where it does, they consider whether a comparable arrangement without the conflict is available
• They approve the matter only if it is in the institution's interest, fair and reasonable
• The decision and the reasons for it are recorded in the minutes or the decision record

6. Conflicts in research

6.1A member with a financial interest relevant to a piece of research must disclose it before work begins. Depending on its nature, the institution will publish the interest alongside the work, assign the work to someone else, or decline to publish. Undisclosed relevant interests are grounds for withdrawal of the work.

7. Violations

7.1If there is reason to believe a covered person has failed to disclose a conflict, they will be told of the basis for that belief and given an opportunity to respond. If a failure is confirmed, the institution will take appropriate action, which may include removal from a role or the end of membership.