Skip to main content
Advocating for people with intellectual, developmental, and other disabilities to lead full and equitable lives.
AHRC New York City

Advocating for people with intellectual, developmental, and other disabilities to lead full and equitable lives.

Section 4.05: Conflict of Interest Policy for Staff of AHRC NYC

Section: 4.05
Issued: 12.31.2005
Updated: 04.11.2023

Purpose

The purpose of this policy is to define conflict of interest, the process for completion of a conflict of interest attestation, and how to report potential conflicts of interest.

Policy Overview

It is the policy of AHRC NYC that its employees avoid conflicts of interest so that employees of AHRC NYC may represent the organization in a positive and ethical manner. All employees must avoid situations involving a conflict between their personal interests and the interests of AHRC NYC. Employees must avoid outside business interests that could compromise an employee’s commitment to the agency – either by dividing loyalties or by diverting the energies and attention owed to AHRC NYC in the normal course of employment. Employees must act in the best interest of the people supported and their families and the best interests of the agency.

Potential conflicts of interest should be promptly reported to the chief compliance officer/ VP of Corporate Compliance.

Potential conflicts include but are not limited to:

  • Ownership by an employee or a member of an employee’s immediate family of a significant financial interest in a business enterprise that does business with, seeks to do business with, or is a competitor of AHRC NYC.
  • Business interests that adversely affect the quality of a staff person’s work or involve the use of agency equipment, supplies, facilities, or name are not permitted.
  • Serving as a director, officer, consultant, or in any other key role in any outside enterprise that does or seeks to do business with or is a competitor of AHRC NYC.
  • Conflict of Interest Policy for Staff of AHRC NYC
  • Staff must not maintain outside employment which:
    • Interferes with scheduled work for AHRC NYC.
    • Impairs the employee’s effectiveness.
    • Results in adverse publicity for AHRC NYC.
    • Conflicts or appears to conflict in any way with the interests of AHRC NYC.
  • Any other arrangement or circumstance, including family or other personal relationships, which might prevent the staff person from acting in the best interest of the agency.
  • Relative of any city and/or state elected officials which can result in any financial interest and/or benefit, direct or indirect. For the purposes of this policy, a relative is defined as a spouse/partner, child, grandchild, sibling.

While it is impossible to present an exhaustive list of all outside personal interests, activities or affiliations that might be considered as being in conflict with the best interests of the agency, two basic principles apply:

  • The interest of the agency and the people we support must take precedence over private business interests.
  • A business opportunity which belongs to AHRC NYC, or which is based on confidential information not available to the public, must not be used for personal gain or for any purpose contrary to AHRC NYC’s interests.

Disclosure of Conflicts of Interest

Upon Hire

Upon hire, all new staff must review the Personnel Practices Manual which includes a section about Conflict of Interest. They must sign a statement that they agree to abide by all of the requirements in the Manual.

Annual Disclosure

All members of senior management must complete the Annual Conflict of Interest Disclosure Form for Senior Management and return it to a designated member of the Corporate Compliance team by July 1 each year. The vice president of

Corporate Compliance reviews the disclosure forms and takes any action necessary to ensure that any conflict of interest is addressed.

All members of the Senior Leadership Team (who are not required to sign the Senior Management disclosure form) and other designated staff must complete the Annual Conflict of Interest Disclosure Form for Senior Leadership Team and Other Designated Staff and return it to a designated member of the Corporate Compliance team by July 1 each year. The vice president of Corporate Compliance reviews the disclosure forms and takes any action necessary to ensure that any conflict of interest is addressed.

The vice president of Corporate Compliance will review findings with the Audit Committee on an annual basis.

Questions Regarding Potential Conflicts

Questions and concerns about potential conflicts must be directed to the vice president of Corporate Compliance.

Investigations

The vice president of Corporate Compliance will make a determination and, if necessary, conduct an investigation of any violation of this policy. Any disciplinary action taken and/or any contingencies to be put in place to resolve the conflict must be documented.

Search AHRC NYC