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CONFLICT
OF INTEREST
Discussion
Potential conflicts of interest infuse many nonprofit
relationships and must be managed successfully to ensure the integrity
of the organization and the research it conducts.
Conflicts can involve individuals as well as the organization
itself if it has a financial interest in the outcome of a study.
The general topic of employee conflicts of interest is addressed
here. Other aspects are
discussed in several places on this web site:
-
Hiring
- At the time of hire, each NPC employee must certify that
he/she is aware of and in compliance with federal conduct and
conflict of interest statutes and regulation.
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Compliance
with statutory requirements – more details about federal conduct
and conflict of interest compliance required in the NPC authorizing
statute.
-
Governance
– how to identify and manage potential conflicts incurred by board
members and key employees.
Note:
This web site does not address conflicts of interest and
financial disclosure requirements of VA and other federal agencies for
personnel involved in research. See
guidance in VA handbooks and other federal agency regulations.
Employee Conflicts of Interest
A conflict of interest exists when
(a) an individual (i.e., director, officer, employee, contactor) has a
relationship or engages in an activity that impairs or adversely
influences his or her judgment with respect to the best interest of the
employer; (b) when the relationship or activity adversely influences the
performance of the employee’s duties; or (c) when the employee
benefits financially, either directly or indirectly (i.e., benefits
family member), based on employment.
Consequently, NPCs may want to have
a conflict of interest policy informing employees that they should avoid
being placed in any situation where conflicts of interest may arise by
(1) refraining from accepting gifts or favors of monetary value, except
those of nominal value (i.e., pens, post-it notes, etc.) and (2) not
engaging in business or professional activities that have or may have
the appearance of conflict with the interests of the NPC or VA.
Employees should be encouraged to
disclose potential conflicts to their supervisors when situations occur
that could cause concerns about conflicts of interest.
Sample Ethical Conduct / Conflict of Interest Policy
All NPC employees are subject to
federal statutes and regulations applicable to federal employees with
respect to conflicts of interest in the performance of official duties.
At the time of hire, each employee signs and submits to the NPC a
"Standards of Ethical Conduct and Related Responsibilities of
Employees" statement certifying awareness of, and compliance with,
these laws and regulations.
We expect employees to avoid
situations that may cause their personal interests to conflict with the
interests of our NPC or to compromise its reputation or integrity. A
conflict of interest, or the appearance of one, occurs when you or a
member of your immediate family uses your position with us for personal
benefit through an investment, association, or business relationship
that interferes with your ability to exercise independent judgment on
our behalf. Disclose any
unavoidable conflicts of interest to your supervisor
Employees may not accept meals or
other gifts of more than a nominal value from salespeople, vendors,
suppliers, or any other solicitors.
A request for an exception to this rule must be submitted to your
supervisor before acceptance.
We encourage you to disclose
potential conflicts to your supervisor when situations occur that could
cause concerns about conflicts of interest.
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