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eQHealth Solutions, Inc. CONFLICT OF INTEREST POLICY

eQHealth Solutions, Inc. CONFLICT OF INTEREST POLICY.

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eQHealth Solutions, Inc. CONFLICT OF INTEREST POLICY

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  1. eQHealth Solutions, Inc.CONFLICT OF INTEREST POLICY The purpose of this policy is to protect eQHealth Solutions when it is contemplating entering into a transaction or arrangement that might benefit the private interest of eQHealth Solutions and other business entities affiliated to it and those of employees, officers, directors, managers and sub-contractors or might result in a possible excess benefit transaction. Board members, employees, officers, directors, managers, and sub-contractors have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest.

  2. CONFLICT OF INTEREST (con’t) Definitions Conflict of Interest – An actual or potential conflict of interest occurs when a board member, employee, manager, sub-contractor or interested party is in a position to influence a decision in any matter involving his/her partner, business associate, health care facility or association of health care facilities or immediate family member in which he/she has a monetary interest. For the purpose of this policy, a relative is any person who is related by blood or marriage, or whose relationship with a board member, employee, or designated committee member is similar to that of persons who are related by blood or marriage.

  3. CONFLICT OF INTEREST (con’t) Definitions (con’t) Organizational Conflict of Interest – Due to other activities or relationships with other persons or entities, a person or entity is unable or potentially unable to render impartial assistance or advice to the company or client, or the person/entity’s objectivity in performing the contract work is or might be otherwise impaired, or a person/entity has an unfair competitive advantage.

  4. CONFLICT OF INTEREST (con’t) Definitions (con’t) Financial Interest – A person/entity has a financial interest if the person/entity has, directly or indirectly, through business, investment, or family: • An ownership or investment interest in any entity with which eQHealth Solutions has a transaction or arrangement • A compensation arrangement with eQHealth or with any entity or individual with which eQHealth has a transaction or arrangement. • A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which eQHealth is negotiating a transaction or arrangement. • A direct or indirect ownership or investment interest (including an option or non-vested interest) in any entity that exists through equity, debt, or other means and includes any indirect ownership or investment interest no matter how many levels removed from a direct interest. • A compensation arrangement with an entity.

  5. CONFLICT OF INTEREST (con’t) Definitions (con’t) Compensation includes direct or indirect remuneration as well as gifts or favors that are not insubstantial. A financial interest is not necessarily a conflict of interest. A person/entity who has a financial interest may have a conflict of interest only if the Board or designated committee of the Board decides that a conflict of interest exists.

  6. CONFLICT OF INTEREST (con’t) Procedures • In connection with any actual or possible conflict of interest, eQHealth and other entities affiliated to it, and those of employees, officers, directors, managers, and sub-contractors must disclose the existence of any financial interest or organizational conflicts and be given the opportunity to disclose all material facts to the Board or its designated committee. • The Board or its designated committee shall decide if a conflict of interest exists.

  7. CONFLICT OF INTEREST (con’t) Procedures (con’t) • If the Board or its designated committee has reasonable cause to believe a person/entity has failed to disclose actual or possible conflicts of interest, it shall inform the person/entity of the basis for such belief and afford them an opportunity to explain the alleged failure to disclose. • If, after hearing the person/entity’s response and after making further investigations warranted by the circumstances, the Board or its designated committee determines the person/entity has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

  8. CONFLICT OF INTEREST (con’t) Annual Training Each Board Member, manager, employee, and sub-contractor shall annually receive refresher training on the Conflict of Interest Policy and shall annually sign a statement which affirms that they: • Receive a copy of the conflicts of interest policy, • Read and understand the policy, • Agree to comply with the policy, and • Understand that eQHealth is a 501(c) 3 organization and in order to maintain its federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes.

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