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RSNA
Policy on Conflict of Interest and Confidentiality |
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For
Volunteer Leaders – Board Members and Committee Chairs |
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I. |
CONFLICT OF INTEREST |
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Purpose |
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The Radiological Society of North
America (RSNA) is organized for the express purpose of promoting and
developing the highest standards of radiology and related sciences through
education and research. The integrity of its Board of Directors, Board of Trustees
of the Research and Education Foundation, and committee chairs is essential
to achieving this purpose. It is critical to the integrity of RSNA that those
serving in elected or appointed positions avoid conflicts of interest and the
appearance of conflicts of interest. All decisions and actions must be made
solely for the benefit of RSNA, without regard to personal considerations.
Concern is raised when financial or other personal consideration may
compromise, or have the appearance of compromising, an individual’s
professional judgment. The purpose of this statement is to guide RSNA and its
leadership in the management of potential conflicts primarily through
disclosure of all financial or other interests which might be construed as
resulting in an actual, potential, or apparent conflict in regard to
decisions that may arise from recommendations, assessments, or opinions,
given individually or as part of a group. Nothing
in this policy statement should be regarded as creating a presumption of
impropriety in the existence of financial interests or other relationships of
a commercial nature, or in service to another organization in a leadership
capacity. Instead, the statement represents recognition of the many factors
which can influence judgments and a desire to make as much information as
possible available to the Society. |
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What is a Conflict of Interest? |
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A
conflict of interest may occur whenever an individual or member of that
individual’s immediate family (including spouse, dependent children
or other financially dependent family members) has a direct or indirect
interest or relationship, financial or otherwise, that may influence the
individual’s ability to exercise independent judgment in any action affecting
RSNA or its members. A conflict of interest may exist in those instances
where the actions or activities of an individual on behalf of RSNA would (a)
result in personal gain or advantage, (b) have an adverse effect on RSNA’s
interests, or (c) obtain a gain or advantage for a third party. A conflict of
interest does not necessarily make an individual ineligible to serve, but may limit the individual’s ability to
participate in certain activities or discussions. |
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Reporting a Conflict of Interest |
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Attached
to this Conflict of Interest Policy is a Disclosure
Statement for members of the Board of Directors, Research and Education
Foundation Board of Trustees, and committee chairs to utilize in disclosing
beneficial interests that may give rise to a conflict between an RSNA
position or responsibility and another professional, business, or volunteer
position or responsibility. If an individual has a potential conflict
relating to business before the RSNA Board of Directors or one of its
committees, that individual should immediately report the potential conflict
to the Chair of the Board. |
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Situations
that should be disclosed are: |
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1. |
A director, officer, committee chair
or member, consultant or advisor, or employee of any person or entity having
contractual relations or business dealings with RSNA or engaging in
activities that could be reasonably construed to affect RSNA or its members.
Only persons or entities with contractual relations or business dealings
resulting in income or in-kind remuneration of over $5,000 in any one year or
in excess of $10,000 over a three-year period shall be required to be
disclosed pursuant to this paragraph. |
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2. |
An investor, directly or indirectly,
in any company or other entity that could be considered a conflict of
interest pursuant to the attached policy. Any equity interest exceeding
$25,000 (except when invested in a diversified publicly traded fund not
controlled by the covered individual) in a commercial entity must be
disclosed if the company is an entity having an investment, licensing, or
other commercial interest potentially related to RSNA. |
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3. |
A
member of an advisory board, review panel or consultant service, or an
officer or board member of an entity (including a professional association)
that may have conflicting priorities or competing interests with RSNA. |
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4. |
In
a position to supervise or otherwise exercise authority over research or
other work that is being conducted pursuant to a grant or agreement with a
commercial entity. |
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5. |
Serving
another professional organization in a fundraising capacity. |
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Determination of Conflict of Interest |
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The
Disclosure Statement, to be filed annually by members of the Board of
Directors, R&E Foundation Board of Trustees, and committee chairs will be
used to determine any actual, potential or apparent
conflicts of interest in matters before any RSNA committees or Board of
Directors. The determination of a conflict and the action to be taken will be
the responsibility of the Chairman of the Board. If the potential conflict
involves the Chairman, the RSNA President will make the determination. |
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Resolution of Conflicts |
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When an actual conflict of
interest is determined to exist, the conflict will be disclosed to the
appropriate Board or Committee,
and the disclosure will be recorded in the minutes. In the case of a more
serious conflict, the individual will be requested to recuse himself or
herself from consideration of any matter giving rise to concern. This
includes withdrawing from the meeting or activity so as not to participate in
any discussion or vote on the matter. For continued serious conflicts that
cannot be remedied by disclosure and recusal, the individual will be
requested to either divest the outside interest or voluntarily withdraw from
the position held in RSNA. Failure to do so may result in involuntary removal
from the RSNA activity in question. |
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II. |
CONFIDENTIALITY |
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It is important that confidential
Society information disclosed in the context of Society activities is not
disclosed or used outside
that context. Therefore, the members of the Board of Directors, R&E
Foundation Board of Trustees, and committee chairs are required to
acknowledge in writing, the need for maintaining such confidentiality. Each
such person shall keep confidential and shall not disclose, either during or
after the person’s period of service to the Society, all confidential or proprietary
information of the Society, such as: nonpublic financial information,
information about employees of the Society, nonpublic information relating to
plans and strategies of the Society, information relating to membership
applications, matters discussed in executive session, and any other
information which common sense and good judgment suggest should be kept
confidential. |
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III. |
USE OF RSNA NAME |
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Acknowledgement |
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I acknowledge and agree that (i) I have read and understand the conflict
of interest policy of RSNA, (ii) I understand the requirements for reporting any
potential conflict during my tenure as a member of the RSNA Board of
Directors, member of the Research and Education Foundation Board of Trustees,
or as chair of an RSNA committee, (iii) to the best of my knowledge, information and belief I have disclosed all beneficial
interests that may create a conflict of interest on the attached form; and
(iv) I shall report any additional conflicts to the Board of Directors as
they rise. I
further state that I will abide by the confidentiality provisions of this
policy and will not use, or permit the use of my position
with the Society or the Society’s name to imply a Society endorsement of any
product or service or to imply Society support of an opinion or activity of
mine. |
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Signature: |
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Name: |
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Date:
Adopted June 2006 |
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Note:
The interests of the spouse, dependent children or
other financially dependent family members of an individual subject to this
disclosure must be aggregated with the financial interests of such individual
when determining whether any disclosure pursuant to the above thresholds is
required. |