Conflicts of Interest
Conflicts of interest occur any time relationships or personal financial interests influence, or might reasonably appear to influence, your ability to make an objective and fair decision based solely on what is best for Kaiser Permanente and the members and patients we serve.
Areas to Consider
Here are some common conflict of interest situations. If you don’t see the information you need here, ask your manager or compliance officer or email: EthicsandComplianceCOI@kp.org.
Why Conflicts of Interest Matter
We are trusted partners for our members, co-workers, and the communities we serve. When we act in a positive and thoughtful manner in our behaviors and decisions, we reinforce trust.
Undisclosed perceived or actual conflicts of interest can undermine this trust and compromise the reputation of Kaiser Permanente. By recognizing, disclosing, and avoiding conflicts of interest, we create transparency and strengthen our ethical culture.
If you believe you may have a conflict of interest, talk to your manager and compliance officer or email: EthicsandComplianceCOI@kp.org.
Our busy schedules and quick decision-making often help us move faster but can also cause us to overlook important details. We think we recognize a scenario and instinctively handle it the way we did previously. However, some situations can appear very different when we take a moment and look at them from another person’s point of view.
Asking yourself some quick questions can help prevent conflict of interest situations.
- What is my personal interest?
- What is my business role?
- Could my personal interests interfere with my obligations to KP?
- What is the unbiased right decision?
Your Responsibilities
Every employee has the responsibility to Recognize, Disclose and Avoid.
Recognize
A conflict of interest occurs when your personal relationships and financial interests could influence your decisions on behalf of Kaiser Permanente.
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Important
Think about your outside interests, and whether they might be perceived to be a conflict of interest. Think especially when you change roles, or life’s circumstances change: Here are some examples.
Change in your role:
- New role, promotion, or change in accountabilities.
- New vendors.
- Change in staff reporting relationships.
Change in life’s circumstances:
- Spouse or other close family member changing jobs.
- You or a family member buy a business or start a new business.
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Disclose
Situations that present a conflict of interest, should be disclosed to your manager and compliance officer. Documented disclosure protects both you and Kaiser Permanente.
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Important
Many situations can be addressed in a mutually-agreed manner. These can include further disclosure to other decision-makers or recusal from certain activities. In some cases, divestment of assets may be required.
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Avoid
Avoid situations that may create or give the appearance of a conflict of interest.
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Important
It is important to note that situations that give even the appearance of a conflict of interest should be avoided. These should be avoided. Examples of situations to avoid because they are conflicts of interest, or situations that give the appearance of a conflict:
- Gifts from a vendor, even if you are not involved in contracting, approving payments, or oversight of the vendor.
- Meals or travel expenses from a vendor, even if it is part of a conference or other meeting with the vendor.
- Discounted conference admission from a vendor. – Except as part of KP’s contractual agreement with the vendor.
- Meals or travel expenses from a third party acting on behalf of a vendor.
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Gifts and Entertainment
Employees can accept gifts worth $25 or less from members and patients who want to say thank you to KP. But if the gift is worth more than $25 and is a food item, it must be shared with other employees. If you are unable to share, then it cannot be accepted.
For more information, view the full policy by clicking here:
Conflict of Interest: Vendor Relationships, NATL.EC.016.
Scenarios
Holiday Gifts
Situation:
A holiday gift from a sales manager for a vendor I work with was delivered to me. It is an expensive-looking serving tray. What should I do?
Guidance:
The gift can only be accepted if shared with other KP employees. You can take it to a breakroom for all to share. If this is not a possibility, the gift should be returned as soon as possible. You also should inform the giver that your employer’s policy does not permit you to accept gifts over $25.00.
For more information, view the full policy by clicking here:
Conflict of Interest: Vendor Relationships, NATL.EC.016.
Business Meals
Situation:
A vendor’s implementation manager has offered to pay for my lunch when he comes on-site for meetings. I don’t want to miss the opportunity to conduct business during lunch time.
Guidance:
You can lunch with the vendor representative, but your meal should be less than $25 and disclosed to your supervisor in advance in writing or paid for by Kaiser Permanente, or by you personally, depending on the circumstances. Many restaurants will split the bill, especially if you ask beforehand. If you expect that there will be several similar meetings over the course of the project, it is acceptable to alternate with your business partner on payment for the meal.
For more information, view the full policy by clicking here:
Conflict of Interest: Vendor Relationships, NATL.EC.016.
Personal Relationships
It is natural for people to favor family and friends. When an employee manages a vendor or employee who is a family member, it is difficult to be objective about performance.
Scenarios
Promotion
Situation:
I am dating a co-worker. We have kept the relationship confidential until now. My manager is leaving, and I have been offered the position. What should I do.
Guidance:
You cannot be the manager of someone you are dating. If you and your partner want to continue the relationship, you should speak with your Human Resources consultant. Your Human Resources Consultant may work with you to find alternative equivalent positions for one or both of you.
Hiring employees
Situation:
I need an additional resource for two months in the summer for clerical and administrative work. My daughter would be perfect, and she is available this summer before she starts college. Hiring her would reduce the administrative load in recruiting for a short-term assignment.
Guidance:
A direct reporting relationship is not appropriate. It does not matter whether the daughter is hired as an employee or as a contingent worker. Neither is appropriate.
If you hire a family member, your staff may not trust that you will be impartial. Morale will suffer.
Selecting Contractors
Situation:
I oversee a recently formed large department. Our scores on team effectiveness are very low. I have budget to hire work with my teams to build their efficiency. My sister owns a mid-sized company that works primarily on team-building for new teams. I sincerely believe could really help turn around the working relationships. What should I do.
Guidance:
First, consider carefully and as objectively as possible, whether your sister’s firm is the best choice for the assignment. This is a conflict of interest. If, after consideration, you still think this is best for the team, disclose the relationship and discuss the situation with your manager and compliance officer. There may be ways to mitigate the conflict of interest or the perception of a conflict of interest. If not, it might be determined that your sister’s company cannot be considered for this assignment.
Business Ownership and Investments
Conflicts of interest can arise because of personal financial interests or investments held with vendors, customers, or competitors.
Scenarios
Sales and Marketing Business
Situation:
I own a business selling plastic household goods at parties and to other people I know. People at work might like the opportunity to buy these products. Is it acceptable to sell these products at work.
Guidance:
It is good to remember that our facilities exist to fulfil our mission of improving the health of our members and the communities we serve. When you sell products at work, it distracts from this mission, by distracting co-workers from their jobs, so is not permitted. In addition, you should not use your position, or any Kaiser Permanente assets, including phones and computers, to conduct personal business.
Care Facility
Situation:
My spouse and I own a residential care facility in our community. It is not part of my role to advise members or their families on residential care. However, I am sometimes asked if I know of a suitable facility. Do I need to disclose this ownership?
Guidance:
This situation needs to be disclosed to your manager and compliance officer. They can provide guidance on how to politely decline providing a recommendation developed in consultation with your compliance officer. You may sincerely believe that your facility provides a high level of care, at a good value, however, your evaluation is not objective. While your recommendation is not officially on behalf or KP, it will appear so to a member.
Outside Employment
Outside employment could interfere or conflict with Kaiser Permanente’s mission or your work; especially if you are working for, consulting with, or representing any Kaiser Permanente vendor or competitor.
Scenarios
Teaching Roles
Situation:
I have an opportunity to teach a class at a nearby college. Is this a conflict of interest? Is there anything specific I need to do?
Guidance:
If you are teaching a subject area related to your responsibilities at Kaiser Permanente, it is recommended that you be transparent and disclose to your manager.
In many situations, this is not a conflict of interest. However, depending on your position there may be specific risk areas to consider. You will need to make sure you understand what information is confidential or proprietary and cannot be shared with students.
“Moonlighting” at Retail
Situation:
I am a licensed pharmacist employed in management at KP. Is it appropriate to also do a few shifts at a retail pharmacy?
Guidance:
Disclosure is recommended. If the risk of disclosure of confidential information is low, this activity may be permitted as long as it does not interfere with job responsibilities at KP.
Software Development
Situation:
I am a software developer at working on the implementation of a software product at KP.
Is it appropriate to also work as a developer with the vendor while they are ironing out the bugs in the application?
Guidance:
This is a conflict of interest because your personal interest in additional income could affect your decision-making with respect to the acceptability of the vendor’s product. Usually there would not be a a way to mitigate the conflict and you would not be permitted to accept this assignment while also working in your role at KP.
If you are considering this, disclose to your manager and compliance officer, and think there is a way to mitigate the conflict of interest, talk to your manager and compliance officer.
Political Contributions
As a nonprofit, tax-exempt organization, Kaiser Permanente must follow important rules about political engagement. One of those rules is that KP can’t support or oppose political parties or candidates. When you’re at work, you must follow this rule, too. Doing so protects our nonprofit status. It also creates a welcoming environment for everyone. And, it allows us to continue earning the trust of the communities we serve.
What you can and can’t do
- You can be politically active on your own time. You must be clear that you aren’t representing KP. For example, you can’t say you’re representing KP when you’re at a political rally or when you’re engaging in political activities on your personal social media.
- You can’t support or oppose political parties or candidates at work. For example, when you’re working in a KP facility, you can’t wear a hat or T-shirt promoting anyone running for office.
- You can’t use KP resources to promote a political party or candidate. You’re welcome to volunteer outside of work for a political campaign. However, you can’t use KP facilities, computers, phones, or email accounts to support your efforts. For example, you can’t print flyers at work supporting a political party or candidate.
For more information, view the full policies by clicking here:
Prohibited Partisan Political Activities Policy, NATL.HR.008
Code of Ethical Conduct — Kaiser Permanente’s Principles of Responsibility
Scenarios
Campaigning
Situation:
I want to work on the re-election campaign for my current representative. What do I need to do?
Guidance:
Civic engagement is encouraged. However, HP/H must be strictly non-partisan. This enables us to continue as a tax-exempt organization, using all our revenue to improve our members’ and communities’ health. All the work that you do on the campaign must be on your own time. You must not use any Health Plan or Hospitals assets or equipment. Do not do campaign work from your office, do not use the telephones or computers issued to you for any campaign work, including providing information about the candidate to your colleagues. Do not use your company issued credit card for any expenses, and do not give donations of HP/H owned equipment.
Board Service
Board service refers to serving as a member of a board of directors or an advisory board for an organization (nonprofit, corporate, or governmental). It involves strategic oversight, fiduciary responsibility, and advocacy for the organization’s mission.
Scenarios
Serving on a board
Situation:
You are asked to join the board of a local non-profit organization that helps the community. You are excited about the opportunity but are unsure if this could be a conflict of interest.
Guidance:
Employees may volunteer to serve as members on the board of directors or advisory boards of community-based non-profit organizations, for-profit organizations, or trade associations as long as the organization’s activities do not conflict with the mission or business of KP, or with the employees’ job responsibilities. Prior to volunteering on an external board, employees are required to disclose the board service in writing to their supervisor and Ethics and Compliance (Compliance-Operations@kp.org), and to obtain approval from their current supervisor.
For more information, view the full policies by clicking here:
Conflict of Interest: Vendor Relationships, NATL.EC.016.
Nonprofit Board Service, NATL.CB.002.