Learn about how Blue KC prevents conflicts of interest from interfering with business practices.
We each ensure that we do not engage in activities that conflict with, or are otherwise incompatible with, our responsibilities as Blue Cross and Blue Shield of Kansas City (Blue KC) employees.
A conflict of interest can be defined as a situation where your personal interests or activities could influence your judgment or your decisions, and therefore your ability to act in the best interests of Blue KC. A conflict of interest includes activities that may only appear to influence your judgment or decisions. Because even the appearance of a potential conflict of interest can cause our business partners and customers to question our motives, we must ensure that our personal interests do not create such a situation.
A conflict of interest between our personal interests and professional responsibilities is often characterized by situations where we, or members of our family, stand to receive a personal benefit, whether financial or otherwise, as a result of our actions in connection with the company. For example, if you or your spouse have a financial interest in a company seeking to do business with Blue KC, your loyalty to the company would be in direct conflict with your personal financial interests. The same conflict would be present if you or your spouse have a financial interest in a Blue KC competitor. For this reason, Blue KC generally will not purchase goods or services from an employee, or from a business in which Blue KC is aware that an employee or a member of an employee's immediate family has a substantial interest. Limited exceptions may be made with management approval, if they are in the best interests of Blue KC, are fully disclosed, and the appropriate precautions are taken. In addition, in order to avoid the conflicts prohibited by this Standard, Blue KC employees must disclose any financial interests that they or immediate members of their family have in either Blue KC competitors or in companies doing business (or seeking to do business) with Blue KC.
Another example of a conflict of interest would be where a company seeking to do business with Blue KC offers you a gift or loan. The acceptance of a gift or loan from a potential business partner could compromise your ability to act in the best interests of Blue KC, and must therefore be declined. This prohibition does not apply to routine business courtesies.
We must also take care to ensure that any secondary employment we engage in does not create an actual or potential conflict of interests. For this reason, Blue KC employees may not serve as consultants to, or as directors, officers or part-time employees of, Blue KC competitors, subcontractors, vendors, or others seeking to do business with Blue KC. Again, limited exceptions may be appropriate with proper approval, full disclosure, and appropriate safeguards in place.
Except for travel advances, Blue KC may not, directly or indirectly, including through any subsidiary or affiliate, extend or maintain credit, arrange for the extension of credit, or renew an extension of credit in the form of a personal loan.
Compliance with this Standard requires full disclosure on the part of all employees. Accordingly, you must disclose all actual or potential conflicts of interest so that Blue KC can determine whether a conflict exists and if so, what actions should be taken to eliminate or avoid the conflict. At least once per year the Audit Services and Compliance Division will distribute a conflict of interest questionnaire to all Blue KC Directors and Officers. The questionnaire may also be distributed to certain employees based upon their particular job duties. Persons to whom the conflict of interest questionnaire is distributed must answer all questions fully and accurately, and must certify as to the accuracy of the information given. All other employees will complete the Corporate Declaration, including a conflict of interest statement, in conjunction with the annual Partnering For Performance appraisal.
Responses to the conflict of interest questionnaire or Corporate Declaration will be reviewed by the Audit Services and Compliance Division, and if material conflicts appear to exist, by a member of the Legal Services Division. The Legal Services Division may use outside counsel for further review if indicated. Blue KC’s Compliance Officer and Compliance Committee, with advice from the Legal Services Division, will then determine what recommendations should be made to eliminate or avoid any identified conflicts of interest, and will document their decisions and recommendations with respect to such actual or potential conflicts.