Purpose:
To enable affected individuals to understand, identify, manage and appropriately disclose actual, potential or perceived conflicts of interest.
Scope:
All Caris-affiliated facilities including all corporate departments, groups, and divisions.
Introduction
Consistent with our Code of Conduct, no Caris colleague may enter into any employment, transaction or other arrangement that may cause or be perceived to cause a conflict of interest.
Affected individuals, as defined below, are required to complete a Conflict of Interest Certificate (attached). Within 60 days of becoming an affected individual, such individual must review this policy and complete the attached Conflict of Interest Certification. At least annually thereafter, affected individuals must review the conflict of interest policy.
At any time during the year, when an actual, potential, or perceived conflict of interest arises, an affected individual must revise his or her certification form to disclose such interest and contact his or her supervisor. The responsibility to promptly report such actual or potential conflicts rests with the affected individual.
The SVP, Chief Compliance Officer or designee will review disclosures with supervisors and determine which require further action. Supervisors will discuss action with the affected individual.
Nothing in this policy prohibits a facility or the Corporate office from defining “affected individuals” to include more members of their staff than listed in the definition below.
Definitions
Affected Individuals: Affected individuals include all Workforce Members.
Conflict of Interest: An actual, potential or perceived conflict of interest occurs in those circumstances where a colleague’s judgement could be affected because the colleague has personal interest (including a financial interest) in the outcome of a decision over which the colleague has control or influence. A personal interest exists when a colleague or a member of his or her immediate family stands to directly or indirectly gain as a result of a decision.
Immediate Family: For purposes of this policy, immediate family shall include any child, stepchild, grandparent, parent, stepparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law or sister-in-law of the affected individual and any person (other than a tenant or employee) sharing the household of the affected individual.
Financial Interest: A financial interest includes income or other remuneration, as well as investments and ownership interests in excess of 5% of the total interest. It does not include stock, bonds, and other securities sold on a national exchange; mutual funds; or certificates of deposits and other depository accounts at financial institutions.
Appendix: