Conflict Of Interest Policy

The UnityPoint Health Board of Directors has adopted a system-wide Conflict of Interest Policy for the purpose of setting forth organizational beliefs and policy with respect to conflicts of interest; identifying those corporate entities and individuals subject to certain requirements under the Policy; and explaining the requirements and activities associated with identifying and ethically resolving conflicts of interest on the part of individuals affiliated with the organization.

Identification and resolution of conflicts of interest which may exist on the part of directors, officers, key employees and certain members of the medical staffs is required by standards promulgated by the Joint Commission on Accreditation of Health Care Organizations, the Internal Revenue Code and Treasury Regulations governing tax-exempt organizations, and by requirements placed upon providers by Medicare and Medicaid program regulations. UnityPoint Health has adopted this Policy not only to meet the above-stated requirements, but also as a matter of ethics, corporate responsibility, sound management practice, and to afford protection, where available, in cases in which some duality of interest exists. In such situations, full and timely disclosure of the individual's interests in connection with transactions which are otherwise proper and fair to the organization provides protection against individual liability.

The System-wide approach to identification and resolution of conflicts of interest includes the following elements: Resolution of the UnityPoint Health Board of Directors in regard to conflicts of interest; Article V, Section 6, Paragraph b of the UnityPoint Health Corporate Bylaws assigning conflicts of interest responsibilities to the Board Development Committee; this Policy, and disclosure questionnaires completed annually by individuals subject to disclosure requirements under this Policy, the Internal Revenue Code, or Medicare/Medicaid program regulations.

A single, system-wide committee consisting of the Executive Director of Internal Audit, UnityPoint Health Compliance Director and the General Counsel shall review all annual disclosure questionnaires and interim supplemental disclosures from designated categories of persons within the company who are subject to this policy.

Definition of Conflict of Interest: A conflict of interest may occur if a UnityPoint Health covered Person's outside activities, personal financial interests, or other personal interests influence or appear to influence his or her ability to make objective unbiased decisions in the course of the Covered Person's job responsibilities. A conflict of interest may also exist if the demands of any outside activities hinder or distract a Covered Person from the performance of his or her job or cause the individual to use UnityPoint Health resources or UnityPoint Health confidential information for other than UnityPoint Health purposes. UnityPoint Health Covered Persons are obligated to ensure they remain free of conflicts of interest in the performance of their responsibilities at UnityPoint Health.

Outside Business Activities: A Conflict of Interest may exist where a Covered Person or the individual's family member engages in Outside Business Activities that conflict with the best interests of the Company, resulting in a financial or non-financial gain to the Covered Person or other individual's family member engaging in such conduct. "Outside Business Activity" means services as a director, trustee, officer, owner, committee member, employee, independent contractor, consultant, advisor, agent or similar position with another organization (regardless of whether the organization is charitable or for-profit in nature).

Corporate Opportunity: A Conflict of Interest may exist when a Covered Person or the individual's family member seeks to take advantage of a corporate opportunity or enables another interested person or other organization to take advantage of a Corporate Opportunity that he or she has reason to believe would be of interest to the Company. For purposes of this policy, Corporate Opportunity means a business opportunity presented to an officer, director, key employee or reporting physician that UnityPoint Health :

  1. Is financially able to undertake;
  2. Is in the Company's line of business and would be of practical value to the Company;
  3. Has an interest in or reasonable expectation of the opportunity, and the officer, director, key employee or reporting physician, by taking the opportunity, will create a conflict with the Company; and
  4. The opportunity, in fairness, should belong to the Company.