Conflict of Interest Policy

POLICY STATEMENT

In order to maintain the highest standard of trust and integrity among our clients and the people we service, it is expected that all individuals associated with Encompass Medical Experts Inc. carry out their duties honestly, responsibly and in full accordance with the highest ethical and legal standards. It is recognized that perceived, potential, and actual conflicts of interest may arise as individuals perform their duties and carry out related activities.

As a first step in identifying and resolving conflicts of interest, all employees and independent contractors who are authorized to make decisions on the behalf of Encompass Medical Experts Inc. shall immediately disclose any perceived, potential or actual conflict of interest. Employees are expected to maintain the highest standard of trust and integrity.

DEFINITION

For the purposes of this policy the following definitions apply:

  • Associate: An immediate family member (Including a parent, grandparent, sibling, spouse (including a life partner), child, grandchild, son-in-law, daughter-in-law, brother-in-law, parent, close friend or legal guardian.
  • Conflict of Interest: Any situation which places the individual in an actual, potential or perceived conflict between his or her private, personal or other interests (or the private, personal or other interest of an Associate of the individual) and the individual’s duties to Encompass Medical Experts Inc. Of particular concern are conflicts of interest that result in, or may result in the following:
    • The execution of Encompass Medical Experts Inc duties being influenced to the detriment of Encompass Medical Experts Inc;
    • A gain, advantage or showing of preference to an individual or an Associate of an individual, to the detriment of Encompass Medical Experts Inc.
    • The use of privileged or confidential information for personal gain;
    • A reciprocal benefit or arrangement between an individual and an external organization or individual;
    • Outside interests or activities that erode the trust and confidence in the integrity of Encompass Medical Experts Inc.

An improperly managed or undisclosed conflict of interest will not be tolerated by Encompass Medical Experts Inc. An individual’s failure to properly disclose an actual or potential conflict of interest may be grounds for corrective action, up to and including termination of his/her employment or contract with Encompass Medical Experts Inc.

PROCEDURES

  • Whether a conflict of interest exists will depend upon the circumstances of each case. It is the responsibility of all individuals associated with Encompass Medical Experts to declare situations of actual or potential conflict of interest as soon as a situation arises.
  • Employees will be required to sign a Conflict of Interest Declaration Form at the time of hire.
  • All new employees will review our Code of Conduct policy within two weeks of hire.
  • Employees will confirm that the appropriate conflict of interest declarations have been made during the annual performance review process.

EXAMPLES

The following are examples of Conflict of Interest situations only and are not intended to be exhaustive. A situation or action does not need to occur as described to constitute a conflict of interest. Further, a potential or perceived conflict, as well as an actual conflict must be reported. It is important to consider the potential for conflict in each situation, and to disclose a situation where you are unsure if it could constitute a conflict of interest.

  • In a case where an assessment is being conducted and during the assessment it is identified that the medical professional has previously treated the claimant/patient and therefore the medical assessment breaches the “Patient/Doctor” Independent relationship.
  • Where the name or address of the client is known to the employee, the file will automatically be transferred to another employee within the organization.
  • As part of our new client process, Encompass Medical Experts will review and confirm prior to contract signature that no conflict of interest exists between current and new clients. If any issue is identified we will be transparent and disclose such conflict or potential conflict. If we are unable to come to a resolution, we will decline our boarding our new client.

GIFTS

With the exception of offering our clients or potential clients branded stationary, at Encompass Medical Experts Inc. we respect our client’s internal policies on what is acceptable gift exchanges and therefore we comply with such requirements.

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