AHG Policy on Conflict of Interest and Disclosure

The AHG will follow this policy in all of its Council and committee deliberations.

Definition. A conflict of interest is defined as having multiple interests in a particular decision being made that could potentially influence an individual’s opinion. Standard definitions include:

  • A set of circumstances that creates a risk that professional judgment or actions regarding a primary interest will be unduly influenced by a secondary interest.
  • A conflict between the private interests and the official responsibilities of a person in a position of trust.

Such conflicts of interest include having a direct or indirect financial, consulting, or personal interest; decisions which will bring direct financial benefit, gifts, or favors to an individual other than through the success of the organization itself, are clear Conflicts of Interest. Other examples include but are not limited to:

  • Current employee of or consultant/contractor to an entity entering into relationship with the organization.
  • Ownership in or investor/stockholder of an entity entering into relationship with the organization.
  • Former employee of or consultant/contractor to an entity entering into relationship with the organization.
  • Providing consulting or advisory services to the organization beyond what is defined in the bylaws, which will result in direct or indirect remuneration.
  • Holding a position on the board of directors of an entity entering into relationship with the organization.
  • Direct family or personal relationships with an entity or individual entering into relationship with the organization.
  • Current or past employment, contract with, investment, ownership in, or personal relationship with an entity that provides similar services as the organization.

Disclosure and Decision Making.
Council members and officers shall disclose in writing on an annual basis all potential conflicts of interest to fellow Council members. To facilitate this process Council may develop specific COI forms to be completed and signed by Council members and officers. In addition, Council members and officers are obligated to disclose any potential conflicts of interest immediately as they arise, including an updating of any COI forms. These records will be kept on file and accessible to all Council members wishing to review them. Council members, Officers, and others involved in a decision-making process (such as members of a committee) shall disclose all Conflicts of Interest pertaining to any specific question at hand; this can be done verbally and recorded in minutes, or in writing depending on the conflict and decision at hand. Council members and officers are encouraged to recuse themselves voluntarily from any decisions in which their judgment may be unduly influenced by a conflict of interest. In lieu of voluntary recusal, the remaining Council members or members of the committee in question will review and make a final determination regarding any Conflicts of Interest. Disclosing a Conflict of Interest does not necessarily mean disqualification from discussing and deliberating on a decision to be made. Conflicts of Interest can be categorized in the following manner:

  • Definite conflict. The individual with the conflict can be excluded from part of the deliberation / discussion, and generally abstains from voting in the case of lack of consensus. In all cases the individual will have the opportunity to fully share his/her opinion to inform the decision-making process. An example would be direct financial compensation from services rendered or decisions made.
  • Probable or possible conflict. The individual with the conflict fully participates in all discussions, and is excluded from voting (in the case of lack of consensus) only if the other Council and/or committee members are in agreement that an abstention is warranted. Examples would include a current or prior relationship with the entity or individual(s) pertaining to the decision being made, that could potentially result in a benefit, financial, personal, or otherwise, to the individual.
  • No perceived conflict. If the remaining Council and/or committee members have reasonable cause to believe an individual has failed to disclose actual or possible conflicts of interest, it shall inform the individual of the basis for such belief and afford the individual an opportunity to explain the alleged failure to disclose and to determine if the oversight was in good faith or not.

The AHG Conflict of Interest Disclosure Form must be filled out annually by all Governing Council members in accordance with AHG policy.