Conflict of Interest Policy

Employees

StayWell Custom Communications is a subsidiary of MediMedia USA, which expects its employees to devote their full work time, energies, abilities and attention to its business. Employees are expected to avoid situations that create an actual or potential conflict between the employee's personal interests and the interests of the company. Employees who, because of other work or activities, cannot make this commitment may be asked to end their employment with the company.

A conflict of interest exists when an employee's loyalties or actions are divided between the company and a competitor, supplier or customer. Employees who are unsure whether a certain transaction, activity or relationship constitutes a conflict of interest should discuss it with their manager of a member of management for clarification. The president and CEO of MediMedia USA must approve in writing any exception to this guideline.

Some examples of the more common conflicts that should be avoided by all employees are:

• Accepting personal gifts or entertainment from competitors, customers, suppliers or potential suppliers.

• Working for a competitor, supplier or customer while employed by the company.

• Engaging in self-employment in competition with the company.

• Using proprietary or confidential information for personal gain (i.e., insider trading) or to the company's detriment.

• Having a direct or indirect financial interest in or relationship with a competitor, customer or supplier.

• Acquiring any interest in property or assets of any kind for the purpose of selling or leasing it to the company.

• Committing the company to give its financial or other support to any outside activity or organization without the appropriate written management authorization.

Failure to adhere to this "conflict of interest" policy, including failure to disclose any conflicts or to seek an exception, may result in disciplinary action up to and including termination of employment.

Freelance writers

Independent contractors who want to write for StayWell must avoid situations that create an actual or potential conflict of interest between the writer's personal interests and StayWell's interests in presenting fair, impartial and credible articles.

Potential conflicts of interest include:

• Having a direct or indirect financial interest in or relationship with a source or some other third party that may be affected by an article the writer is preparing. Such interests might include employment, consultancies or stock ownership (in excess of $10,000) in a health care or pharmaceutical firm, trade group or organization. This may include the financial interests of a spouse or a child.

• Accepting personal gifts, entertainment, accommodation, transportation or other services or items of value from sources or potential sources.

Not all such situations may pose a conflict. Writers should disclose any potential conflicts to the editors, even if they're not sure they constitute a conflict. Difficult cases may be referred to the Quality Oversight Committee for guidance. Writers who have separate relationships with health care, trade or pharmaceutical organizations should disclose this to the editor before using any sources from those organizations in articles they write for StayWell.

Authors who have a problematic conflict of interest in a specific subject area will not be permitted to write about that issue for StayWell. However, they are not barred from writing about those issues for which they do not have a conflict of interest.

Questions about our policies

Members can e-mail questions about our policies to  policies@staywellsolutionsonline.com.

We commit to a response within 24 hours on business days.

Approved by members of the Quality Oversight Committee 9/15/2006