In addition, participants in NSGC-related activities are obligated to disclose the positions they hold or relationships they have with other organizations or entities that may conflict, directly or indirectly, with their NSGC activities. They also have an obligation to disclose any significant financial interest in, or other relationship with, an entity having a “commercial interest” in the activity. A commercial interest may exist not only where the entity’s products or services are under consideration by NSGC, but also where the entity’s products or services are in competition or potential competition with those under consideration. By the disclosure of such interests, other participants will have the opportunity to take potential biases into consideration. In addition, the Board of Directors (or, as applicable, committee members) will be in a better position to determine whether the participant may have an interest in conflict with the interests of NSGC.
To help assure full disclosure of any actual or potential COI, all participants in NSGC-related activities, including the NSGC’s staff, officers, directors, and committee members must comply with this Policy and annually sign and submit a Disclosure Form (a copy of which is attached hereto) (i) acknowledging that he/ she is aware of and has read the Policy; and (ii) disclosing the information described above. If, subsequent to any such annual disclosure (but prior to execution of a new annual Disclosure Form), an NSGC officer, director, or staff or committee member becomes aware of a relationship required to be so disclosed, that officer, director, staff, or committee member shall promptly make the required disclosure by submitting a revised Disclosure Form identifying the organization, business, group, entity, etc., and describing the nature of the relationship.
It is the responsibility of the disinterested members of the Board of Directors or, as applicable, committee members, to interpret and apply this Policy. And, inasmuch as the Policy is stated in general terms, the Board of Directors or its designee(s) should use their best judgment applying this policy.