HAEi Conflict of Interest Policy for Employees/Independent Contractors

Definition

Generally, a conflict of interest may occur if an interest or activity influences, or can be perceived as influencing, the ability of an individual to exercise objectivity or impairs the individual’s ability to perform his or her responsibilities in the best interests of HAE International (hereafter referred to as ‘HAEi’ or ‘the Organization’).

General Guidelines

HAEi Employees/Independent Contractors are expected to conduct themselves and their business-related responsibilities in a manner that reflects

  • the highest standards of ethical conduct,
  • abiding by Organization’s core principles of honesty and integrity at all times, and
  • adherence to all applicable US laws and regulations as well as those governing the country/countries in which business is being conducted.

HAEi’s Employees/Independent Contractors are obligated to avoid ethical, legal, financial, or other conflicts of interest involving the Organization.

HAEi recognizes and respects Employees/Independent Contractor’s right to engage in activities outside their contract with the Organization provided that such activities do not in any way conflict (or appear to conflict) with the fundamental business, financial, and operational interests of HAEi.

It is not possible to define all the circumstances and relationships that might create a conflict of interest. The following activities illustrate conflicts of interest that should be avoided and disclosed, as applicable, in accordance with this policy. The list is not all inclusive and is intended to provide guidance:

  1. Engaging in any activity which conflicts and/or competes with the interests or purposes of the Organization.
  2. Serving on the board of organizations (for profit, non-profit or governmental) that are current or potential grantees of the Organization.
  3. Simultaneous employment (or contractor status) with another organization (for profit, non-profit or governmental) that is a competitor of, grantee, or potential grantee to the Organization.
  4. Engaging in any financial business or other relationships with current or potential grantee to the Organization.
  5. Accepting substantial gifts or excessive entertainment from a supplier or partner of the Organization.
  6. Participating in civic or professional organizational activities in a manner that divulges confidential company information.
  7. Misusing privileged information or revealing confidential data to outsiders.
  8. Using one’s position or knowledge of the Organization’s affairs for personal gains.
  9. Engaging in practices or procedures that violate antitrust laws, commercial bribery laws, copyright laws, discrimination laws, campaign contribution laws, or other laws regulating the conduct of company business.
  10. Serving as (or having a family member–spouse, domestic partner, parents, siblings, children–serve as) a representative for any HAE medicine or other HAE product while engaged as an Employee/Independent Contractor for HAEi.