Including Dealing with Confidential Information and Information Concerning Publicly Traded Securities

ASH is dedicated to advancing the specialty of hematology. To accomplish this mission, the Society provides support for a variety of activities in the areas of research, education, training, and advocacy. The integrity of ASH, and the activities it undertakes, depends on the avoidance of conflicts of interest, or even the appearance of such conflicts, by the individuals involved with those activities.

On occasion, situations may exist in which an individual serving the Society in an elected or appointed position, as a speaker, or as an employee has some outside interest that would constitute a conflict of interest or that could be perceived as constituting a conflict of interest. Generally, a conflict of interest could be said to exist when individuals have material interests outside the Society, which could influence or could be perceived as influencing their decisions, actions, or presentations.

Most often, the type of interest resulting in a conflict would be financial, such as, for example, when an individual has an association with a third party through receipt of a research or other type of grant or stipend, an ownership interest, an employment relationship, or a consultative or advisory arrangement. A conflict of interest also exists if an individual involved with the Society has a close relative (with whom income is shared) who is either employed by or has any financial interest with a third party. In some situations a conflict of interest may exist even though the conflict does not arise out of financial considerations. For example, a member of the Society’s Executive Committee may have a fiduciary responsibility as a member of the board of directors of some other organization. If the interests of that organization were contrary to the interests of the Society, a situation could exist in which the individual could not fulfill his or her fiduciary responsibilities to both organizations. A conflict of interest would exist, even though it might not be related to personal financial gain. Other examples include conflicts that arise due to collaborations or competition with other investigators or institutions.

Perhaps the most important aspect essential to conflict avoidance is commitment by all who serve ASH to hold each other accountable and be willing to call on each other to act in accordance with this policy. The atmosphere we desire is one where people are comfortable asking questions without feeling awkward or accusatorial, and where recusing oneself from participation in discussions that might be perceived as constituting a conflict is the norm rather than the exception.

To facilitate this, the Society has developed disclosure forms, which are to be completed annually by anyone involved in Society activities - committee members, speakers, editors, authors, study section and abstract reviewers, and Senior Staff. Specific policies and versions of the disclosure form for each role an individual may play in the Society are detailed in the respective forms. Additionally, all of those completing the form are expected to provide notification in writing if a potential conflict of interest arises that has not previously been disclosed.

For each activity, a point person has been identified to be responsible for enforcing the conflict-of-interest policy. All committees, including the Executive Committee, have appointed a conflict-of-interest compliance officer; the Editor of Blood oversees all conflicts that may involve associate editors, reviewers, and authors; and all Continuing Medical Education (CME) accredited activities rely on full disclosure by every speaker and author, as well as oversight and monitoring by the Committee on Educational Affairs.

It must be emphasized that the Society's policy on conflict of interest is not intended to dissuade qualified candidates from Society service. Indeed, each individual's special interests and outside activities can enhance his or her ability to better serve the organization. In many instances, those interests and activities clearly do not constitute an actual conflict of interest. However, as a nonprofit organization, it is appropriate that ASH have a system in place to assure that those with conflicts do not participate in decisions in which they have a real or perceived conflict.

If a Conflict of Interest Exists
When an individual has a conflict of interest on a particular subject, he or she should not take any action on behalf of the Society concerning that subject, participate in discussions on the subject or cast a vote on it. In addition, anyone with a conflict of interest on a particular subject must ensure that third parties they deal with concerning that subject are aware they are not acting on behalf of the Society. In most situations, no further action will be required. However, in some instances, the nature of the conflict of interest may be so substantial that the individual will be asked to discontinue the non-Society activity resulting in the conflict or relinquish his or her position with the Society.

Situations may arise in which one or more members of a deliberative body (such as a committee) believe that someone has a conflict of interest but the person perceived as having the conflict does not agree. In order to address this situation the Society’s Executive Committee has adopted the following policy:

“When the question of a conflict exists, it will be fully discussed, with each side given the opportunity to state why they believe a conflict does or does not exist. The final decision on whether the individual has a conflict of interest will be made by a majority vote of the deliberative body at issue. The member alleged to have a conflict of interest shall be disqualified from voting on the question and shall leave the meeting before a vote is taken on the issue.”

Policy on Dealing with Confidential Information and in Publicly Traded Securities
In the course of serving the Society, individuals may from time to time receive confidential information. This might occur, for example, in connection with the review, selection, or publication of abstracts.

It is against the law and the Society’s policy for anyone who has material, non-public information relating to a specific company listed on a stock exchange to take personal advantage of that information by trading in the stock of that company or by disclosing such information to outsiders, such as friends, relatives, or other employees, who may trade on the basis of such information. It is the Society’s policy that individuals in possession of material non-public information relating to a specific company must maintain the confidentiality of such information and refrain from trading until there has been disclosure of that information to the public. Information is considered “material” if it is information that an investor would consider important in deciding whether to buy, sell, or hold any publicly traded security or would be likely to have a significant effect on the price of such security. Such material information may include new discoveries, pharmaceutical product approvals, or progress on pharmaceutical product development issues. These announcements are generally made as news releases to ensure that the information is made available to all members of the investing public on an equal basis.

Protection of Confidential Information
Anyone who receives confidential information in the course of serving the Society shall keep such information confidential and not disclose it to third parties, unless required under a legal obligation to do so. Confidential information includes, but is not limited to, unpublished data, ideas, arguments, manuscripts, or slides, unpatented inventions, and other information that has not been authorized for disclosure.

Those serving the Society are responsible for making sure that confidential information is not disclosed to any unauthorized recipient, whether deliberately, or through carelessness. Materials that contain confidential information should be stored securely and shared only with those persons having a need to know the same. Special care should be taken when discussing confidential information in public places and when corresponding through electronic media such as electronic mail, telephone voice mail, fax, or videoconferences.