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University Health Network
                                            Policy & Procedure Manual
                                  People & Culture: Conflict of Interest



                   Policy


                   At University Health Network (UHN), all employees, medical staff, volunteers, and
                   independent contractors must disclose any potential or actual conflict of interest. It is
                   essential that employees, medical staff, volunteers, and contractors maintain the highest
                   standard of public trust and integrity.

                   An improperly managed or undisclosed conflict of interest will not be tolerated by UHN.
                   Any employee, medical staff member, volunteer, or independent contractor who is found
                   to have engaged in such conduct will be subject to disciplinary action, up to and
                   including termination of employment, volunteer assignment, or contract with UHN.

                   Requirements have been established to deal primarily with:

                        •  gift acceptance
                        •  business relationships
                        •  vendor relationships
                        •  family relationships
                        •  consensual intimate relationships

                   Note: Research staff, also refer to Conflict of Interest of Research Personnel policy
                         40.90.002.


                   Gift Acceptance

                   Staff shall not solicit gifts from patients and/or their families, and should abstain from
                   accepting gifts that fall outside the considerations listed below. Prior to determining
                   whether to accept a team gift or an individual gift, the staff member recipient must
                   consider:

                        •  whether the patient/family member giving the gift is mentally competent;
                        •  whether the patient/family expects anything in return for giving the gift;
                        •  the potential for negative feelings on the part of other patients who may not be
                            able to or choose not to give gifts to staff members;
                        •  the monetary value of the gift;
                        •  cultural norms applicable to gifts that are applicable in the circumstances, if
                            any;
                        •  any applicable regulatory requirements; and
                        •  if refusal of the gift would harm the patient-staff member relationship.

                   Gifts made to a UHN-associated foundation or to UHN are not considered personal gifts
                   to individuals.

             This material has been prepared solely for use at University Health Network (UHN). UHN accepts no responsibility for use of this material by
               any person or organization not associated with UHN. No part of this document may be reproduced in any form for publication without
                    permission of UHN. A printed copy of this document may not reflect the current, electronic version on the UHN Intranet.
            Policy Number  2.50.002                             Original Date   11/90
            Section      Employee Relations                     Revision Dates   04/93; 07/05; 11/05; 04/09; 04/18; 09/19
            Issued By    People & Culture; Legal Affairs        Review Dates
            Approved By   Executive Vice-president, People, Culture   Page     1 of 4
                         & Community
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