4/15/2015

Colorado SIM Office Conflict of Interest Statement

Re: SIM Advisory Board & SIM Workgroups

Definitions: Conflict of interest is defined as any financial or other interest which conflicts with the service of the individual because it could 1) significantly impair the individual’s objectivity or 2) could create an un-fair competitive advantage for a person or organization. The term also applies to not only the personal financial interests of the individual but also to the interests of others with whom the individual has substantial common financial interests if these interests are relevant to the functions to be performed. An individual should not serve as a member of a committee with respect to an activity in which a critical review and evaluation of the individual's own work, or that of his or her immediate employer, is the central purpose of the activity, because that would constitute a conflict of interest, although such an individual may provide relevant information to the program activity. Bias relates to views stated or positions taken that are largely intellectually motivated or that arise from the close identification or association of an individual with a particular point of view or the positions or perspectives of a particular group. Potential sources of bias are not necessarily disqualifying for purposes of committee service. Indeed, it is often necessary, in order to ensure that a committee is fully competent, to appoint members in such a way as to represent a balance of potentially biasing backgrounds or professional or organizational perspectives. Some potential sources of bias, however, may be so substantial that they preclude committee service (e.g., where one is totally committed to a particular point of view and unwilling, or reasonably perceived to be unwilling, to consider other perspectives or relevant evidence to the contrary.) Immediate family member is defined as (i) father, mother, brother, sister, daughter, or son of the member; and/or (ii) the spouse of the member; and/or (iii) father, mother, brother, sister, daughter, or son of the member’s spouse. Disclosure: Prior to taking office as a member of the SIM Advisory Board or a member of a workgroup, a member must deliver to the SIM Office a written declaration of the participant’s business interests or representational interests the member has to a known past, current, or potential recipient of SIM funds or any funds guided by the SIM Office or SIM Advisory Board. The written declaration must be updated annually to reflect any material changes 1

4/15/2015

and must include business interests or representational interests of the member’s immediate family members or business partners. When a member or his or her business partner and/or his or her immediate family member has any interest as described above in any proposal or request for funds which comes before the SIM cooperative agreement, that member must, prior to any discussion or vote relating to such matter, publicly disclose the nature of the interest in the matter on consideration, remove himself or herself from any discussion relating to such matter, and abstain from voting on the matter. Any member with such a conflicting interest may not vote or initiate or participate in any discussion on any requests for funds that compete with the proposals or requests in which the member has the interest. All declarations of conflicts of interest and abstentions from voting shall be recorded in the minutes of the SIM Advisory Board or SIM workgroup meeting. Below there are scenarios that should be disclosed to the SIM Office. Please note, examples below are not all inclusive and it is requested that the participant utilize their judgment to determine the proper information to disclose. Examples of such disclosure may be, but not limited to the following: 

Worked in the past on a SIM workgroup and your organization is eligible to receive funding



Participant is assigned to a newly developed SIM workgroup and the participants organization is eligible for funding



The participant is on the SIM Advisory Board and the organization is eligible for funding



Participant has provided guidance, formally or informally to the process, and was unaware of the newly developed Conflict of Interest (COI) policy.

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