Conflict of Interest Policy Statement

A. Introduction

This conflict of interest policy applies to School-Based Health Alliance (SBHA) board members, employees, and contractors. Its purpose is to avoid, reduce, or manage actual, potential or perceived conflicts of interest in performance of the individual’s duties and responsibilities. In addition to the standards of ethical conduct set forth in this unit’s policy, there are conflict of interest statutes that prohibit certain conduct by Alliance employees.

B. School-Based Health Alliance Representatives

Representatives include, but are not limited to: volunteer Board of Directors, Officers, employees, certain contracted parties or agents, and other designated individuals in decision-making roles.

C. Principles

Disclosure: SBHA Representatives are to fully disclose financial and non-financial relationships, including their employment, ownership interests, memberships, and consultant agreements.  Reporting is to occur before appointment or election and annually thereafter.

  1. SBHA Representative is expected to update his or her Disclosure Questionnaire whenever any material change occurs in his or her relationships.
  2. In the course of SBHA’s meetings or activities, the SBHA Representative is to disclose any direct or indirect interests in a transaction or decision that potentially could be a conflict of interest.

Evaluation: Reporting these personal and other business relationships generally does not prevent an individual from working with or volunteering for the SBHA. SBHA will evaluate non-financial and financial relationships for actual or perceived conflicts based on the nature of SBHA Representative’s position(s) and scope of decision-making authority, the substantiality of the relationships, the pervasiveness of the conflict and whether additional measures are needed to protect the integrity and reputation of the SBHA Representative and the School-Based Health Alliance.

Resolution: Conflicts may be resolved by having the SBHA Representative refrain from deliberating and/or voting on the particular transaction or matter in which he or she has an interest; and otherwise refrain from exerting any influence on SBHA to affect a decision. However, other measures may be required by SBHA, depending on the nature of and the ability to reasonably manage the conflict. Resolution will be based on the facts and circumstances of each individual situation, but may in some cases require action up to and including the withdrawal of the individual from the conflicting relationship or from the SBHA position.

Specific to Board of Directors: As with SBHA staff, many of SBHA’s current and former board members are subject matter experts in areas related to school-based health. This is very valuable intellectual capital that enables SBHA to be frequently sought out as a project partner or for technical assistance. Therefore, the Board has adopted a policy that allows current and former board members to be paid to assist on engagements where their expertise can add value. For complete transparency, current board members are required to disclose to the board when they are engaged for their expertise and are to refrain from any votes on decisions regarding the specific engagement in which they are involved.

D. Confidentiality

When a volunteer is a director, committee member, or other active participant in another organization, the volunteer will not disclose or use confidential or proprietary information of SBHA or otherwise make disclosures that could be injurious or disadvantageous to SBHA.

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