Conflict of Interest Policy

Purpose

The purpose of this Policy is to provide guidance in identifying and managing potential and actual conflicts of interest involving the Food and Drug Administration Alumni Association (the "Association"). The Association recognizes that directors and officers may take part in financial, business, and other activities outside their work for the Association, but potential and actual conflicts of interest raised by those activities must be disclosed promptly to the Association.

Definition of Conflicts of Interest

A conflict of interest arises when a person in a position of authority over the Association is faced with a personal or pecuniary interest that could influence his or her ability to act in the best interests of the Association, make it difficult to perform his or her work for the Association objectively and effectively, or give the appearance that he or she has a conflict.

Generally speaking, an individual is considered to have a potential conflict of interest when (1) he or she, or any member of his or her family,[1] may receive a financial or other significant benefit as a result of the individual's position at the Association; (2) the individual has the opportunity to influence the Association's business, administrative, or other material decisions in a manner that leads to personal gain or advantage; or (3) the individual, or any member of his or her family, has an existing or potential financial or other significant interest which impairs or might appear to impair the individual's independence in the discharge of his or her responsibilities to the Association.

Examples of potential conflicts of interest include the following:

  • A Board member is employed by the company that hosts FDAAA's website.
  • A Board member meets with a representative of an accounting company seeking to sign a contract with FDAAA and accepts a meal at an expensive restaurant from the company representative.
  • The sibling of a Board member owns the conference center where the Board holds its monthly meetings.
  • These examples are not exhaustive. Conflicts might arise in other areas or through other relations; they may not always be clear cut and easy to define. Ultimately, it is the responsibility of each individual to identify any situation that creates or appears to create a conflict of interest and to report it promptly to the Chairperson of the Board of Directors.

Individuals Covered

Persons covered by this policy are the Association's officers and directors.

Disclosure of Conflicts of Interest

Persons covered by this policy must annually disclose or update to the Chairperson of the Board of Directors on the attached Conflict of Interest Disclosure Statement any interests that could give rise to conflicts of interest, such as a list of family members, substantial business or investment holdings, and other transactions or affiliations with businesses and other Associations or those of family members.

In addition, persons covered by this policy must promptly disclose to the Chairperson of the Board of Directors any potential conflicts of interest that arise after submission of the Conflict of Interest Disclosure Statement.

Procedures to Manage Conflicts of Interest

For each interest disclosed to the Chairperson of the Board of Directors, the Chairperson will consult with the Board of Directors and determine whether a conflict of interest exists. Upon such a determination, the Chairperson will: (a) take no action; (b) ask the person to recuse himself or herself from participation in related discussions or decisions within the Association; or (c) consider whether it is appropriate to ask the person to resign from his or her position in the Association. No person may participate in any decision to determine whether he or she has a conflict of interest.

The existence of one of the interests described in Section II does not necessarily mean that a conflict exists; that the conflict, if it exists, is material enough to be of practical importance; or that, if the conflict is material, it is adverse to FDAAA's interests upon full disclosure of all relevant facts and circumstances. In the case of potential conflicts arising through relationships with vendors seeking to do business with FDAAA, the vendor must be selected through a competitive bidding process, and the person with the potential conflict must recuse himself or herself from the selection process.

Records of Proceedings

All records documenting conflicts of interest will be maintained, as confidential materials, in accordance with the Association's Document Retention and Destruction Policy.

Monitoring Compliance

The Board of Directors is responsible for monitoring compliance with this Policy.

[1] For purposes of this Policy, the "family" of an individual includes his or her spouse or domestic partner, ancestors, siblings, children, grandchildren, great-grandchildren, and spouses or domestic partners of siblings, children, grandchildren, and great-children.

Approved by the FDAAA Board of Directors: October 15, 2009