Conflict of Interest Policy
How we prevent conflicts of interest
We safeguard our organization, supporters, and beneficiaries by requiring directors, officers, employees, and contractors to disclose potential conflicts, ensuring transparency, integrity, and accountability in all operations and decisions.
Updated: May 4, 2024
Disclosure of Conflicts
All directors, officers, and key employees of IGI are required to disclose any actual or potential conflicts of interest that may arise in connection with their duties to IGI. This includes the duty to disclose any financial interests, relationships, or affiliations that could influence their IGI-related decision-making in a way that materially benefits themselves.
Review and Management
The Board of Directors (or a designated sub-committee) will review all conflict of interest disclosures and determine whether a conflict exists. If a conflict is identified, the affected individual shall recuse themselves from any related decision-making processes related to the conflicted decision. Further the individual must refrain from voting on a conflicted decision. Finally, the non-conflicted decision makers may request that the conflicted individual(s) leave the decision-making venue, as appropriate.
Documentation
When the Board of Directors makes a decision when there is one or more conflicted Directors, the Board Minutes shall so reflect who was conflicted to ensure that the final vote does not factor in the conflicted Director(s)’s vote. If there is an individual affiliated with IGI who is involved in a decision that (s)he has a conflict in, the Board of Directors will document how that individual’s conflict was accounted for when appropriate.
Annual Disclosure
Directors, officers, and key employees shall provide a written disclosure of any potential conflicts of interest to the Board of Directors at least once per year, if not more when appropriate. This disclosure can take any written form; an email, meeting minutes (or similar) is sufficient. This disclosure shall be updated as necessary to reflect changes in circumstances.
Non-Retaliation
IGI prohibits retaliation against individuals who report conflicts of interest or participate in the resolution process in good faith. Any instances of retaliation shall be promptly investigated and addressed by the Board of Directors who are not conflicted in the investigation.
Acknowledgment
All directors, officers, key employees, and important independent contractors of IGI should be made aware of this Policy, and be promptly sent a copy of this Policy upon request. Failure to comply with this policy may result in disciplinary action, up to and including removal from office, termination of employment, and/or legal action as appropriate.