Survey says: What constitutes a conflict of interest?

Asante’s conflict-of-interest policy applies to the entire workforce, but some leaders will be asked to complete a survey.

conflict of interest

What if a relative asks you to send a little Asante business their way, or a vendor offers you freebies? Maybe you’re tempted to promote your side business at work. Each of these represents a potential conflict of interest — and a possible violation of Asante’s policy.

To keep us all honest, Compliance and Integrity sends a conflict-of-interest survey to select employees once a year. If you’re one of the recipients asked to complete the questionnaire for fiscal year 2022, here are a few things to note.

What qualifies as a conflict of interest?

If you’re influenced by a relationship or outside interest to conduct any activity for personal financial gain, you have a conflict of interest.

Anyone affiliated with Asante should always make decisions fairly and objectively and always act in the best interests of Asante without regard to any personal or a third-party benefit.

Who is required to complete the conflict-of-interest survey?

Although Asante policy applies to all employees, volunteers, physicians and leaders, this year’s survey goes out to Asante Board members, including the Asante Foundation Board; and key employees such as supervisors, managers, directors, executives, purchasing agents and buyers.

All employees must report any potential conflict-of-interest, even if you’re not receiving this year’s survey. To report a potential conflict (for yourself or about someone else), talk to your supervisor, another manager or contact the Compliance and Integrity Department at co********@as****.org.

Refer to Asante’s conflict of interest policies for employees or board members for details.

 What are some examples of potential conflicts of interest?
  • A manager using their title or position to influence Asante’s business agreements with an outside entity where the manager, or their immediate family member, has a direct or indirect financial interest.
  • A purchasing agent accepting anything of value from a vendor to engage or purchase any of its services.
  • A nurse practitioner promoting a personal business to a colleague or patient at Asante.
  • An employee who serves as a director, officer or employee of another organization that does business or competes with Asante.
  • A supervisor or manager who hires a family member who reports through the supervisor or manager.
What happens after reporting a potential conflict?

Investigation and analysis: Once a potential conflict is reported or discovered, Compliance and Integrity investigates to determine the degree of risk. For example, a manager may serve on a board of a local nonprofit that receives funding from Asante. If the manager does not control or decide Asante’s funding for that organization, the conflict presents little to no risk.

Assessment and recommendations: After analysis and fact-finding, the compliance team will document their assessment. They’ll work with leaders or other stakeholders to put measures in place to reduce the risk of any potential conflict.

If they find a violation of Asante’s conflict-of-interest policies, the team may work with HR, leadership or other stakeholders to provide appropriate corrective action.

Reporting: Finally, Compliance partners with Asante’s accounting team to report certain conflict-of-interest data to the IRS as part of Asante’s annual tax reporting responsibilities.

 Learn more
Tags: compliance, conflict-of-interest, policy, survey
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If you have a question, please contact the author or relevant department directly.

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