StayWell Conflict of Interest Policy
StayWell is a subsidiary of MediMedia (hereinafter also referred to as "Company") 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, because of other work or activities, who cannot make this commitment, may be asked to end their employment with the company. Certain employees may be required to sign a confidentiality and/or non-competition agreement.
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 or a member of management for clarification. The president and CEO of the Company or his designee must approve any exception to this guideline, in writing.
Some examples of the more common conflicts that should be avoided by all employees are:
Accepting personal gifts or entertainment, including, but not limited to, trips, event ticket, and alcohol from competitors, customers, suppliers or potential suppliers that is greater than a nominal value (i.e. $50 maximum);
Working for a competitor, supplier or customer while employed by the Company;
Engaging in self-employment in competition with the Company, or at the same time working for and billing 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, may result in disciplinary action up to, and/or including, immediate termination of employment.
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 are 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.
For background information on our medical reviewers, authors and editor, please review StayWell Medical Reviewers and Authors and StayWell Clinical Reviewers, Editors, and Medical Illustrators.
Questions about policies
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Approved by the Quality Oversight Committee, December 2015
Revised: December 2015