Over the past ten years or so, issues around conflicts of interest between physicians and other medical researchers and pharmaceutical companies have occupied a lot of time and energy among the medical and scientific societies that we serve. I want our clients and friends to know that in midst of all the conversations about potential financial conflicts between physicians and pharmaceutical companies, we have not ignored the potential conflicts that exist between ourselves and vendors; i.e. hotels, audio-visual companies, etc. Unfortunately, the industries of association management, meeting planning, hotels and the hospitality industry in general have had too many examples of questionable, or clearly unethical, behavior in the past. There have been too many cases of association executives and meeting planners making site visits to resort hotels where they had very little expectation that they would ever book a meeting; too many cases of hotels willingly treating executives and planners to free stays at their facilities and giving them gifts while also courting their business; in short, too many cases of blatant conflict of interest in the way business has been done. But thankfully, the attitude that such dealings are simply business as usual is changing, and we at PMG want to be an example of conducting business with integrity and in accord with the highest ethical standards.
There are several steps we take to ensure integrity in our business practices. First, we are thoroughly audited every year, and even though the audit has a much broader purpose, one of its side benefits is that it gives us an opportunity to review our policies and procedures with a set of outside auditors every year. With their advice over the years, we have developed policies and procedures for handling money, making deposits, paying bills, and reconciling bank statements that are as close to being air tight as anything I can imagine. For someone on staff to find a way to misappropriate money, either a client’s or ours, they would have to be smarter than I am to do it and get away with it.
Another step we have taken that helps in this area is that we have applied for and achieved accreditation for PMG by the Association Management Company Institute. To maintain accreditation, we have to undergo extensive audits by an outside firm every four years. That audit covers many things, but certainly includes things like our policies and procedures for handling money and our disclosure policies for any involvement we might have with other vendors.
Finally, we have implemented a conflict of interest policy for ourselves. I have copied the full policy statement below. We will be happy to have feedback from any members of PMG client organizations regarding this policy. Our objective is to do our work with the highest level of integrity, and we will gladly accept any advice that helps us achieve that objective.
Conflict of Interest Policy Statement
Part I. The Need for A Conflict of Interest Policy Statement
The need for a Conflict of Interest Policy Statement is inherent in the nature of the business relationship between an association management company and its clients. It is our obligation to place the interests of our clients ahead of our own, to serve them with integrity, to perform our duties and to offer advice that is based on impartial analysis of relevant information. It is our responsibility to eschew pecuniary self-interest as we manage the affairs of clients.
In the reality of everyday business practice, it can sometimes be difficult for an individual to judge if their own actions could inappropriately influence their thinking, their advice to clients, and their decisions on behalf of clients. Some individuals might go to extremes to avoid even the appearance of conflict of interest by, for example, not even allowing a vendor to pay for lunch during a legitimate business meeting. Others might see no problem in accepting a weekend visit at a resort hotel under the guise of a site visit as a possible meeting location in the future.
Because PMG aspires to the very highest ethical standards, we have developed this conflict of interest policy statement as a guide for our employees. Its intent is to provide clear guidance to employees who deal with potential conflicts in their daily activities. The adoption of this Conflict of Interest Policy Statement sends a public message to our clients and the community at large that we are serious about conducting our business with the utmost integrity.
Part II. Standards
Section 1. All employees of PMG should avoid any action which might result in or create the appearance of:
- (a) giving preferential treatment to any organization or person;
- (b) using one's position for personal gain;
- (c) losing complete impartiality or independence; or
- (d) affecting adversely the confidence of the public in Parthenon Management Group.
Section 2. No employee of PMG shall solicit or accept, directly or indirectly, any gift, gratuity, favor or entertainment or any other thing of non trivial monetary value (more than $50) from any person, corporation or group which has, or is seeking to obtain, a business relationship with PMG or a PMG client. Notwithstanding this provision, an employee may accept food or refreshments available in the normal course of a lunch, dinner, or any other meeting or engagement where the employee is properly in attendance for a legitimate business purpose.
Section 3. Employees of PMG will be expected to complete the same conflict of interest disclosure statements as client board members, program committee members, or participants in a client meeting must complete. Although it is unlikely that a PMG employee will have conflicts of the types addressed by our clients’ policies, we must make those disclosures nonetheless, and if a conflict of interest should exist we must abide by the same policies for resolving that conflict as our client members.
Part III. Enforcement
Any employee of PMG who has, or may have, a direct or indirect financial interest, as defined in Part II, Section 2, shall inform his or her supervisor and shall state the nature of such interest. The supervisor should document the nature of the potential conflict, and consult with senior management of PMG and the appropriate officers or committee members of the PMG client to resolve the conflict or to remove the employee from the conflicted situation.