Conflict of Interest and Impartiality Policy
Participation in any business or activity that competes with or is detrimental to AACI – or that could compromise the impartiality or integrity of AACI or its employees – is strictly prohibited.
No employee or subcontractor of AACI may, at any time, directly or indirectly engage in any business or activity that:
- Competes with AACI,
- Harms AACI’s reputation or operations,
- Or compromises, or appears to compromise, the impartiality and integrity of AACI, the individual, or any associated personnel.
Additionally, employees and subcontractors must not use confidential or proprietary information in any manner that could reasonably call into question AACI’s integrity or independence.
Any employee serving on the board of directors or in a similar governance role for a commercial organization must obtain prior approval. If the organization could be perceived as a competitor to AACI, such involvement must be explicitly authorized by the Group CEO.
Employees and subcontractors are also prohibited from holding any financial or other interests—either directly or indirectly – in any business or activity that may reasonably raise concerns about their impartiality, objectivity, or the integrity of AACI. If there is any uncertainty regarding such matters, the individual must consult the Chief Regulatory Officer for clarification.
While investments in equity funds or similar indirect investment vehicles are generally exempt from this policy, all relevant financial interests – including those held by a spouse, cohabitant, or dependent children-must be disclosed if they could potentially create a conflict.
AACI will not accept work from any healthcare organization with which it, or its representatives, have existing business, personal, or familial ties. This restriction applies equally to surveyors, subcontractors, and all AACI-affiliated personnel.
Furthermore, AACI surveyors and subcontractors are not permitted to engage in work for other entities outside the AACI Group without explicit, case-by-case approval from the Group CEO.
Note:
This policy directly supports the requirements of Clause 5.2 – Management of Impartiality – in the ISO/IEC 17021-1:2015 standard. The legally responsible entity for this clause is AACI d.o.o.