SAMPLE POLICY WORK

Scope: This policy covers all individuals associated with Simpl Care Services LLC, including:

• • • •

Employees at all levels

Board members

Volunteers

Consultants and contractors

What Constitutes a Conflict of Interest: A conflict of interest exists when an individual’s personal, professional, or financial interests could potentially influence their decisions or actions in a way that is not in the best interests of Simpl Care Services LLC or its clients. Examples include: • Financial interests in a vendor or service provider used by the agency • Family relationships with clients or other staff members • Serving on the board of a competing organization • Using agency resources for personal gain Management of Identified Conflicts of Interest Policy Statement: Once a conflict of interest has been identified, it must be managed appropriately to minimize its impact on decision-making and ensure ethical conduct.

Procedures:

• Disclosure: All covered individuals must disclose potential conflicts of interest in writing to their supervisor or the designated Ethics Committee (if established). A Conflict of Interest Disclosure Form (see Appendix A) must be completed annually and updated whenever a new potential conflict arises. • Recusal: Individuals with a disclosed conflict of interest may be required to recuse themselves from discussions, decisions, or votes related to the matter in question. The decision to recuse will be made by the supervisor or Ethics Committee, based on the nature and severity of the conflict. • Ethical Decision-Making: When conflicts arise, ethical decision-making guidelines should be consulted (see Appendix B). These guidelines outline a framework for evaluating the competing interests and determining the most appropriate course of action. • Documentation: All disclosed conflicts of interest, recusal decisions, and ethical decision-making processes must be documented in writing and maintained in a confidential file. c. Roles and Responsibilities • Staff, Board Members, and Volunteers: Responsible for identifying and disclosing any potential conflicts of interest in a timely manner. • Supervisors: Responsible for reviewing disclosed conflicts of interest, determining appropriate management strategies (e.g., recusal), and documenting the decision-making process.