Scope

This statement sets forth the policy and procedures of the Wisdom House regarding conflicts of interest that are applicable to the employees of Wisdom House. It is to be noted that the policies and procedures set forth here will be subjected to modification from time to time as deemed necessary by Wisdom House.

Introduction

Defining Conflict of Interest

• There are four ways that conflicts of interest can occur.
• 1. An employee has existing or potential financial and nonfinancial interest that impairs the employee’s independent judgment in the discharge of responsibilities to Wisdom House.
• 2. An employee may receive a material financial benefit or other benefit revealing knowledge or information confidential to Wisdom House.
• 3. Conflict of interest arises not only if there is direct personal interest, but also if there is benefit to the employee’s immediate family member. (employee’s spouse, domestic partner and dependent children)
• 4. A conflict of interest also arises from the situation instead of the character or the action. It follows; therefore, a conflict of interest arises when an employee has financial interest which is in conflict with responsibilities to Wisdom House even if the action is not motivated by financial gains.
• Employees must therefore discharge their responsibilities to Wisdom House by avoiding or minimizing conflicts of interest and respond to them appropriately.

The Policy

Required Disclosures

• The interpretation of the disclosure requirements must be guided by common sense. This means that if a reasonable person has concern about a relationship or financial interest, the matter must be disclosed and approval sought.
• Disclosures related to sponsored projects
• (a) Initial Disclosures
• For the purpose of this section, significant financial interest means anything of monetary value. This includes but is not limited to salary or any other payment for services such as consulting fees, stock option and ownership interest; and intellectual property rights such as patents, copyrights and royalties from such rights.
• Examples of significant financial interest of an employee or a family member includes but not limited to an employment or consulting arrangement and or other financial interest with the proposed sponsor, any proposed subcontractor, vendor, collaborator or any entity affiliated with any of the above.
• (b).
• Subsequent disclosures in connection with sponsored projects. During the duration of the project each employee working on the project and having a significant financial interest must update any initial disclosure annually or at more regular intervals deemed necessary by Wisdom House.
• Further, each employee working in a project must immediately disclose any subsequent significant financial interest at the time it arises.
• 3. Review of Disclosure
• Under this policy the administrator of Wisdom House is designated by the establishment to review all disclosures. His responsibility is to ascertain if a conflict of interest exists and to determine any conditions or restrictions, if any, to be imposed to reduce or eliminate it. Under certain circumstances any conflict or potential conflict of interest may be referred to an outside entity for management.
• 4. Any employee violating any provision of this policy is liable to sanctions up to and including termination of employment