StayWell Conflict of Interest Policy
StayWell expects its employees to devote their full work time, energies, abilities and attention to its business. Employees are expected to avoid situations that create an actual or potential conflict between the employee's personal interests and the interests of the company. Employees, because of other work or activities, who cannot make this commitment, may be asked to end their employment with the company. Certain employees may be required to sign a confidentiality and/or non-competition agreement.
A conflict of interest exists when an employee's loyalties or actions are divided between the company and a competitor, supplier or customer. Employees who are unsure whether a certain transaction, activity or relationship constitutes a conflict of interest should discuss it with their manager or a member of management for clarification. The president and CEO of the Company or designee must approve any exception to this guideline, in writing.
Some examples of the more common conflicts that should be avoided by all employees are:
Accepting personal gifts or entertainment, including, but not limited to, trips, event ticket, and alcohol from competitors, customers, suppliers or potential suppliers that is greater than a nominal value (i.e. $50 maximum);
Working for a competitor, supplier or customer while employed by the Company;
Engaging in self-employment in competition with the Company, or at the same time working for and billing the Company;
Using proprietary or confidential information for personal gain (i.e., insider trading) or to the Company's detriment;
Having a direct or indirect financial interest in, or relationship with, a competitor, customer or supplier;
Acquiring any interest in property or assets of any kind for the purpose of selling or leasing it to the Company;
Committing the Company to give its financial or other support to any outside activity or organization without the appropriate written management authorization.
Failure to adhere to this "conflict of interest" policy, including failure to disclose any conflicts, may result in disciplinary action up to, and/or including, immediate termination of employment.
Independent contractors (for StayWell) must avoid situations that create an actual or potential conflict of interest between personal interests and StayWell's interests in presenting fair, impartial and credible articles.
Potential conflicts of interest include:
Having a direct or indirect financial interest in or relationship with a source or some other third party that may be affected by an article the writer is preparing. Such interests might include employment, consultancies or stock ownership (in excess of $10,000) in a health care or pharmaceutical firm, trade group or organization. This may include the financial interests of a spouse or a child.
Accepting personal gifts, entertainment, accommodation, transportation or other services or items of value from sources or potential sources.
Not all such situations may pose a conflict. Independent contractors should disclose any potential conflicts to StayWell, even if they are not sure they constitute a conflict. Difficult cases may be referred to StayWell Legal Counsel for guidance. Independent contractors who have separate relationships with health care, trade or pharmaceutical organizations should disclose this to StayWell before they work for StayWell.
For background information on our medical reviewers, authors and editor, please review StayWell Medical Reviewers and Third-Party Vendors and StayWell Clinical Reviewers, Editors or Medical Illustrators.
Questions about policies
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Reviewed and Approved by the Quality Oversight Committee: November 30, 2017
Revised: June 2018