Policy No.: FIN-008-C
Category: Financial Management
Owner: Vice-President, Corporate Services
Effective Date: 1 May 2022
Approved By: President & CEO
Next Review: October 2023
To ensure Healthcare Excellence Canada (HEC) fulfils its mission with integrity and to a high ethical standard, including through the avoidance of conflicts of interest, and the reporting of conflicts of interest when they cannot be avoided.
To guide HEC Applicants (as defined below) with a real, potential, or perceived conflict of interest on how to identify and disclose their conflict and the process for dealing with conflict situations.
HEC expects its Applicants to conduct themselves in accordance with the highest standards of integrity, and to avoid situations in which their interests are, or are perceived to be, in conflict with the interests of HEC. Where conflicts cannot be avoided, they must be promptly disclosed in accordance with this policy.
The term “conflict of interest” refers to situations where financial, professional, or other personal considerations may compromise, or have the appearance of compromising, either the applicant’s judgement or that of another individual associated with HEC, in the performance of their duties; or could reasonably be seen as influencing the applicant’s or other individual’s duty to act in the best interests of HEC.
HEC Applicants shall identify and disclose any real or perceived conflicts in writing at the beginning of the relationship. Applicants are required to make the necessary disclosures as a condition of engagement with HEC. HEC application forms will stipulate that all Applicants must fully disclose any relationship with HEC staff and/or board members. Conflicts of interest shall be defined in the terms of reference for all HEC’s merit review and selection panels. Terms of reference shall stipulate rules of disclosure, exclusion, and oversight provisions and requirements for written records.
Situations where a conflict of interest might arise cannot be set out exhaustively but generally could arise in the following circumstances:
HEC, in its reasonable discretion, will evaluate all disclosed conflicts and determine whether a conflict poses an unacceptable risk to the interests of HEC and is thus inconsistent with the individual or organization’s obligations to HEC. There will be no appeal from HEC’s evaluation and determination of an unacceptable risk. The significance of a conflict hinges on the applicant’s role at HEC and the nature of the activity or interest. These will be evaluated on a case-by-case basis.
The principles set out in this policy are to be regarded as illustrative. Applicants are required to meet both the letter and spirit of this policy.
“Applicant” means generally, although is not limited to, a person or organization who receives funds from the HEC as part of their participation in an HEC activity.