Conflict of Interest Policy
A. Introduction
As a Medical Transport and Medical Assistance company, public trust in the integrity and independence of the HI Flying scientific review and decision-making processes as well as HI Flying adherence to high standards for the conduct of its lifesaving activities is essential. It is also acknowledged and desired that employees and others working on behalf of HI Flying (HI Affiliates Partners) have myriad relationships, interests, and memberships that support and benefit the mission of HI Flying. However there are times when these multiple relationships may give rise to or give the appearance of an actual or potential conflict of interest. To protect both HI Flying and HI Flying Affiliates this Policy requires disclosure of relationships by HI Flying Representatives and resolution of any conflicts by AHA to ensure that actions taken are in the best interest of AHA. This protects AHA’s and AHA Representatives’ decision-making from the appearance of bias or improper influence by individual personal or business interests, family or close associates in HI Flying.
B. HI Flying Affiliates
Representatives include, but are not limited to: HI Flying Medical escorts, Medical coordinators, Board of Directors, Officers, committee members, council members, key employees, certain contracted parties or agents, and other designated individuals in decision-making roles.
C. Principles
Disclosure: HI Flying Affiliates are to fully disclose financial and non-financial relationships, including their employment, ownership interests, memberships, arrangements, investments and holdings, including those held by family members, as required on the HI Flying Relationship Disclosure Questionnaire.
Evaluation: Reporting these personal and other business relationships generally does not prevent an individual from working with or volunteering for the AHA. AHA will evaluate non-financial and financial relationships for actual or perceived conflicts based on the nature of HI Flying Affiliates 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 HI Flying Affiliates and HI Flying.
Resolution: Conflicts may be resolved by having the HI Flying Affiliates 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 HI Flying to affect a decision. However, other measures may be required by HI Flying, 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 HI Flying position.
D. Requirements for Certain Positions
Because of the diversity of HI Flying activities and operations, different medical escorts or coordinators and staff positions in HI Flying require specific and distinct procedures for addressing conflicts of interest All procedures must be consistent with applicable law, this Policy and approved by the Conflict of Interest Review Committee (COIRC) or the Audit Committee, as applicable.
E. 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 HI Flying or otherwise make disclosures that could be injurious or disadvantageous to HI Flying.