Subject: Affiliate Conflict of Interest and Disclosure Procedures
Policy No.: Appendix A to Policy FIN-007-C
Category: Financial Management
Owner: Vice-President, Corporate Services
Effective Date: 1 May 2022]
Approved By: President & CEO
Next Review: October 2023
1. Disclosure of Conflicts of Interest
- 1.1Affiliates must complete and submit the Affiliate Conflict of Interest Disclosure Form (Appendix B) at the beginning of the engagement to their staff contact as a condition of engaging with HEC. Affiliates must also complete and submit the Annual Affiliate Conflict of Interest Disclosure Form and Attestation (Appendix C) on an annual basis and immediately upon a perceived or real conflict of interest arising.
For greater clarity this means:
- Prior to engaging with HEC, reporting any actual, potential, or perceived conflicts;
- While engaged with HEC before entering new outside activities or relationships, considering whether a conflict with HEC might be actual, potential, or perceived;
- While engaged with HEC before entering a new activity or relationship outside of HEC;
- Abiding by the decision of HEC on whether the outside activity or relationship constitutes an unacceptable conflict for HEC;
- Agreeing that engagement in an unacceptable conflict will be cause for HEC to terminate its relationship with the affiliate, without further notice.
- 1.2 All information gathered in relation to conflict disclosure is kept strictly confidential and will only be used for the purposes set out in this policy.
- 1.3 The Vice-President, Corporate Services and/or as required the President & CEO will review all Conflict of Interest Disclosure Forms and determine if a conflict of interest exists or may exist in future and if so, how the conflict of interest may be resolved to ensure that the affiliate may continue to carry out their duties and responsibilities to HEC. There will be no appeal from the determination of the Vice-President (Corporate Services) and/or the President & CEO.
- 1.4 The affiliate will be notified of the outcome of the review and will be advised of the steps, if any, that must be taken to resolve the conflict of interest. If the affiliate refuses to follow the required steps to resolve the conflict of interest, HEC may terminate the relationship with them.