Conflict of Interest Disclosure Policy
Purpose
The purpose of this Policy is to:
- Provide clear guidance on recognizing and disclosing conflicts of interest.
- Ensure that individuals associated with On Stage Vacaville act in the best interests of the organization.
- Establish procedures for evaluating, managing, and, if necessary, mitigating conflicts of interest.
Definitions
- Conflict of Interest: A situation where an individual’s personal, financial, or other interests could compromise their ability to act impartially and in the best interests of On Stage Vacaville.
Disclosure Procedures
Identification of Conflicts of Interest
Employees, contractors, vendors, and authorized users have a responsibility to be aware of situations that may give rise to conflicts of interest.
Disclosure Requirement
Any individual who becomes aware of a potential conflict of interest must promptly disclose it to their supervisor, manager, or the HR Department, using the designated disclosure form.
Confidentiality
All conflict of interest disclosures will be treated confidentially to the extent allowed by law. Disclosure information will only be shared with individuals who have a legitimate need to know for evaluation and management purposes.
Evaluation and Management
On Stage Vacaville will evaluate disclosed conflicts of interest to determine the nature and potential impact. Based on this assessment, appropriate measures will be taken to manage or mitigate the conflict.
Management of Conflicts of Interest
Recusal
In cases where a conflict of interest is determined, individuals may be required to recuse themselves from decision-making or activities related to the conflict.
Conflict Mitigation
On Stage Vacaville may implement measures to mitigate conflicts of interest, such as establishing oversight, seeking independent opinions, or modifying business arrangements.
Consequences of Non-Disclosure
Failure to disclose a conflict of interest may result in corrective actions in accordance with On Stage Vacaville’s policies and procedures. Consequences may include additional training, disciplinary actions, or other appropriate measures.
Responsibilities
Identification of Conflicts of Interest
- Employees, Contractors, Vendors, and Authorized Users: Responsible for recognizing and disclosing conflicts of interest promptly and for cooperating with On Stage Vacaville in the evaluation and management of such conflicts.
- Supervisors and Managers: Responsible for receiving and evaluating conflict of interest disclosures, overseeing conflict mitigation measures, and ensuring compliance with this Policy within their respective teams.
- HR Department: Responsible for maintaining records of conflict of interest disclosures and management efforts, providing guidance on conflict resolution, and ensuring compliance with this Policy.
Compliance and Consequences
Non-compliance with this Conflict of Interest Disclosure Policy may result in corrective actions in accordance with On Stage Vacaville’s policies and procedures. Consequences may include additional training, disciplinary actions, or other appropriate measures, depending on the nature and severity of the violation.
Policy Review
This Conflict of Interest Disclosure Policy will be reviewed annually or more frequently if necessary. Updates or changes to the Policy will be communicated to all relevant personnel to ensure continued adherence to conflict of interest disclosure guidelines.