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Conflict of Interest and Staff Gift Acceptance Policy

It is the policy of EngenderHealth that staff will always act on behalf of the interests of EngenderHealth. The objective of this policy is to outline certain circumstances where conflicts or the appearance of conflicts may arise, and to outline how these situations are to be managed.

Review and Disclosure of a Conflict of Interest

EngenderHealth is committed to preserving our reputation. To that end, each staff member will conduct oneself and the business of EngenderHealth in a way that does not harm, but rather enhances, the reputation of EngenderHealth. Staff are expected to conduct themselves in their outside activities in a manner that does not adversely affect their job performance or negatively reflect on EngenderHealth.

Accordingly, EngenderHealth will take positive action to protect its interests when the following conditions exist as a result of an employee’s actions during off-duty hours: (1) When the employee’s conduct causes embarrassment to EngerderHealth or reflects unfavorably on fellow employees and EngenderHealth generally; (2) When outside work activities create comments critical of EngenderHealth by the general public; and (3) When outside work or personal activities adversely affect job performance with EngenderHealth. To mitigate excessive or conflicting demands on their time, employees should avoid outside employment or activities which would impair their effectiveness in carrying out their responsibilities to EngenderHealth. Employees in management and supervisory positions have a commitment to EngenderHealth to be available to perform their responsibilities beyond the standard work schedule and shall not commit themselves to activities or supplemental employment that would interfere with this commitment.

Staff members who, upon reading this policy, believes s/he has something to disclose, must complete the conflict of interest disclosure form available from Human Resources, give one copy to his/her direct supervisor and one to Human Resources.

When in doubt as to whether or not s/he is in a situation with the potential to be in violation of this policy, s/he should err on the side of caution by contacting either his/her supervisor, Director, or the Director of Human Resources and seeking clarification.

Definition and Disclosure of Relationships Outside of EngenderHealth

Staff members shall disclose to their supervisors and Directors those relationships that are most likely to have an impact on work-related and managerial decisions. Examples of such relationships may include, but are not limited to, current service as an officer, director, employee, or consultant at an agency that works in the same field as EngenderHealth, or of an agency that is a vendor to EngenderHealth. This disclosure would also include the relationships of immediate family members, which is defined as the staff member’s spouse, domestic partner, parents, children and siblings, whether by blood, marriage or adoption and anyone else residing in the staff member’s home. This would also include disclosure of relationships with staff employed by donors.

This policy is not meant to rule out transactions between EngenderHealth and other entities or persons where an interest or a relationship between a staff member and such other person or entity exists. This policy is designed to ensure that these relationships have been properly disclosed, documented and approved by appropriate EngenderHealth management.

Remuneration for Outside Work

EngenderHealth full-time staff members are expected to allocate their entire professional work effort to activities that are in line with EngenderHealth’s mission, and, furthermore, that are approved as part of the staff’s employment at EngenderHealth. While EngenderHealth encourages appropriate participation and cooperation with organizations involved in similar endeavors for the public good, it is expected that such relationships will normally be an integral part of regular work and will therefore be paid for by EngenderHealth.

An EngenderHealth staff member is expected to disclose any situation where s/he is performing work outside of his/her employment with EngenderHealth that is related to the agency’s mission. If this type of situation arises, the staff member will complete the disclosure form available from Human Resources and email it to his/her direct supervisor, with a copy to the Regional Human Resources Coordinator or, at HQ, to the Director of Human Resources.

Guidance for managing staff member’s opportunities for remuneration for activities undertaken outside of their work as an EngenderHealth staff member is as follows:

• Honoraria: In those situations where an EngenderHealth staff member receives remuneration (e.g., an honorarium) for a speech, radio/television appearance, or publication, and s/he does so as an EngenderHealth staff member, any fees or gifts with value over $25 are to be remitted to EngenderHealth. There are situations, however, when a staff member spends a considerable amount of his/her own time (e.g., vacation, nights, weekends) working on these speeches or publications. Prior to working on a speech or publication, each staff member should speak with his/her supervisor about the work in question and the fact that remuneration is involved, and obtain supervisor approval for the activity, as well as guidance as to how to handle the remuneration. The supervisor must then obtain approval from the Regional or Program Director. If necessary, the Director may seek advice from the Regional Human Resources Coordinator, or the Director of Human Resources at HQ.
• Work for other organizations/companies: EngenderHealth full- or part-time staff members may elect to perform work during their own time (e.g., vacation, weekends) for another organization. No approvals are needed for work that poses no conflict of interest, and is in no way related to the work of EngenderHealth. However, always remember that what you do may reflect on EngenderHealth. Therefore, before you elect to perform work during your own time, ask yourself how this work may reflect on EngenderHealth. Prior approval must be obtained for a consulting assignment for another organization that is related to activities or fields in which EngenderHealth works.

In these situations, there can be two different scenarios:

1. The consulting agency may ask the staff member to consult as an EngenderHealth employee during normal business hours. In this case, the consulting agency should contract directly with EngenderHealth, citing the individual who will do the work, and will remunerate EngenderHealth directly for the staff member’s time.
2. The consulting agency may ask the staff member to consult as an individual and do the work on his/her own time (e.g., during vacation). In this case, the staff member must disclose this activity and seek approval as noted above to ensure that there is no conflict with EngenderHealth’s work and no opportunity for disclosure of privileged EngenderHealth information during the course of the consulting assignment.

• Medical staff: EngenderHealth recognizes that medical staff may continue to practice medicine and maintain a private practice during his/her employment with EngenderHealth. Staff members who continue to practice medicine outside of EngenderHealth employment must disclose this to his/her supervisor. They must be aware of and fully comply with the laws and regulations regarding possible liability. Staff must clearly delineate EngenderHealth business from private medical practice. They must not give the impression that EngenderHealth endorses, supports, or is engaged in any way in the private practice (e.g., meetings or consultancies may not be conducted at an EngenderHealth office). Staff members agree that EngenderHealth bears no liability for any adverse outcomes relating to the private practice and agree that the individual assumes all liability. Any personal liability insurance must be secured and paid for by the staff member.
• Seconded Staff: On occasion, EngenderHealth staff will be seconded to work in the premises of another organization. The staff member will ensure that his/her counterparts are well aware of the employment relationship with EngenderHealth. The staff member will consult regularly with his/her EngenderHealth supervisor to avoid any possible conflict of interest. The staff member, upon consultation with his/her supervisor, must decline any assignment that may be detrimental to EngenderHealth interests.
• Board membership: Staff members who are invited by organizations connected or relevant to their EngenderHealth assignment to serve as trustees or directors on the board of other organizations, or in some similar capacity, must disclose and seek approval for such positions, as noted above. Remuneration or honoraria for such positions may be kept by the staff member, but must be disclosed. Additionally, the staff member must coordinate with his/her supervisor to determine the extent to which the number of days required for Board service would normally be construed as EngenderHealth time (typical work days/hours) or must be taken as vacation or personal time.

Publications and Presentations

The dissemination of EngenderHealth’s technical expertise so that it may be applied in new situations is an important aspect of EngenderHealth’s work. Clear, accurate, articulate descriptions of useful findings can broaden the impact of EngenderHealth efforts and enhance the reputation of the organization and of the individual staff members. To this end, EngenderHealth encourages staff to accept speaking engagements and to write articles, incorporating preparation time for these endeavors into their personal/professional development workplans, as agreed to by their supervisors.

Publications and presentations for publication should be reviewed by the individual’s supervisor for approval of the topic, content, and authorship prior to the staff member preparing the publication/presentation. “Publications” include but are not limited to: brochures, pamphlets, informational sheets, newsletters, annual reports, books, journal articles, all forms of electronic media (e.g., CD-ROMs, Power Point presentations, web-content). When the content of a presentation or article is derived chiefly from EngenderHealth activities, EngenderHealth must be credited.

Employees agree that EngenderHealth shall solely and exclusively own all rights in and to any work created in connection with employment with EngenderHealth, including all data, documents, information, copyrights, patents, trademarks, trade secrets or other proprietary rights in and to the work, all underlying rights to the work, worldwide and in perpetuity.

EngenderHealth has the exclusive right to publish, translate, reproduce, deliver, use and dispose of EngenderHealth materials described above and data resulting from work performed by employees including in-country developed materials and to authorize others to do so.

EngenderHealth reserves the right to review any proposed publications arising from the work performed by employees while employed by EngenderHealth and to request that its name be associated or disassociated with such publications.

Contact with the Media

Staff may not represent to the media that s/he is speaking or writing on behalf of EngenderHealth or that his/her views represent the views of EngenderHealth unless permission has been received from one's supervisor to do so. If an employee has contact with the media which is related to their work/expertise utilized in their employment by EngenderHealth, the interview must attribute them in their role as an EngenderHealth staff person and needs to be approved by the Director of Communications and Marketing.

Disclosure and remittance of gifts over $25.00

An EngenderHealth staff member, or member of his or her immediate family, may not accept commissions, gifts, payments, entertainment, services, loans, or promises of future benefits from suppliers, governments, subcontractors, subgrantees, partners, or counterparts. Excepted from this policy are gifts under $US 25.00, and meals and/or social invitations that are in keeping with good business ethics and do not obligate the staff member or have an impact on decision-making.

There are situations when EngenderHealth vendors send unsolicited gifts to an EngenderHealth staff member or department/office in appreciation for EngenderHealth’s business. Should the gift be less than $US25.00, the staff member may keep the gift. If the gift is valued at greater than $US25.00, it must be forwarded to the Country or Regional Director to be shared with others in the office via a raffle. At HQ, the gift must be given to the Director of Human Resources who will raffle the item off at an agency-wide function (e.g., the year-end party or mid-year picnic). The staff member should communicate this practice to the vendor.

Vendors who send gifts to EngenderHealth staff at the end of the year will be sent a letter by the Development Division explaining that we do not allow personal gifts to staff members but encourage instead donations to EngenderHealth.

Staff with Procurement and Purchasing Responsibility

Staff members with responsibility for issuing or approving orders for the purchase of goods or services may not have a material interest in any supplier to EngenderHealth. Staff members whose immediate family have an interest in a supplier of goods or services are prohibited from issuing or approving purchases to those suppliers. This provision does not prohibit a staff member’s relative from doing business with EngenderHealth as long as this relationship is fully disclosed to the staff member’s direct supervisor and Director, and the staff member recuses him/herself from any decisions pertaining to the purchase. Moreover, competitive bidding procedures must be in place and properly followed as per EngenderHealth’s standard operating procedures.

Confidentiality

EngenderHealth employees agree that all knowledge and information that they may receive from EngenderHealth or from its employees is proprietary information of EngenderHealth and shall be treated as confidential. Proprietary information includes but is not limited to materials, information or ideas relating to EngenderHealth’s business, operations, services, methods and procedures, inventions, processes and technical data and any other information acquired by or as direct result of employment by EngenderHealth. EngenderHealth’s proprietary information shall for all time and for all purposes be regarded by employees as strictly confidential and held in confidence, and solely for EngenderHealth’s benefit and use. This clause shall not apply to disclosures required in connection with a regulatory, judicial or administrative proceeding having the force of law.

Upon the termination of employment, employees shall surrender to EngenderHealth all EngenderHealth proprietary information in the employee’s possession, including without limitation, duplicates, facsimiles and notes relating thereto. Consultants shall promptly direct all inquiries relating to confidential and proprietary information from third parties to EngenderHealth.