TITLE: Conflict of Interest - Employees CURRENT EFFECTIVE DATE: 03/01/2020
REFERENCE NUMBER: HR.PHS-E.317 PAGE 1 of 7
SCOPE: PHS-E PURPOSE: To define Presbyterian’s Policy regarding Conflicts of Interest. The objective in administering this policy is to: • avoid the creation of a Conflict of Interest or the appearance of a Conflict of Interest; • avoid favoritism or the appearance of favoritism; • avoid the inhibition or compromise of communication, decisions, or performance; and • deter harassment or the creation of a hostile environment in the workplace. POLICY: Policy Statement
Employees are to avoid a Conflict of Interest or an appearance of a Conflict of Interest.
Employee Disclosure
Employees are required to disclose to their manager or the Compliance Department the following situations or relationships: • Personal relationship, • Business relationship with any individual or company, • Ownership interest in another business, • Work for another employer, • Personal gain or offers of personal gain from entities that sell goods or services to Presbyterian. Managers are required to partner with a Human Resources Business Partner or a Senior Employee Relations Representative to determine if a Conflict of Interest exists. All Senior Leaders and Directors, as well as employees involved in vendor contracting or government grants, will be required to complete an online Conflict of Interest Statement annually. Failure to complete the Conflict of Interest Statement annually, within 30 days of assignment, could result in corrective action up to and including termination.
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