Conflict of Interest Policy for StayWell or Krames Consumer Health Library

StayWell Employees

StayWell expects its employees - who develop or author and medically review health content for StayWell (also known as SCHL or StayWell Solutions® Online) and Krames Consumer Health Library (also known as Krames CHL) - to devote their full work time, energies, abilities and attention to its business. Employees are expected to avoid situations that create an actual or potential conflict between the employee's personal interests and the interests of the company. Employees, because of other work or activities, who cannot make this commitment, may be asked to end their employment with the company. Certain employees may be required to sign a confidentiality and/or non-competition agreement.

A conflict of interest exists when an employee's loyalties or actions are divided between the company and a competitor, supplier or customer. Employees who are unsure whether a certain transaction, activity or relationship constitutes a conflict of interest should discuss it with their manager or a member of management for clarification. The President and CEO of the Company or designee must approve any exception to this guideline, in writing.

Some examples of the more common conflicts that should be avoided by all employees are:

• Accepting cash payments, personal gifts or entertainment, including, but not limited to, trips, event ticket, and alcohol from competitors, customers, suppliers or potential suppliers that is greater than a nominal value.

• Working for, transactions with, or serving in the management of competitors, vendors/suppliers, contractors, or customers while employed by the Company.

• Engaging in self-employment in competition with the Company, or at the same time working for and billing the Company.

• Using proprietary or confidential information for personal gain (i.e., insider trading) or to the Company's detriment.

• Having a direct or indirect financial interest in, or relationship with competitors, customers, contractors, or suppliers/vendors.

• Acquiring any interest in property or assets of any kind for the purpose of selling or leasing it to the Company.

• Committing the Company to give its financial or other support to any outside activity or organization without the appropriate written management authorization. 

Failure to adhere to this "conflict of interest" policy, including failure to disclose any conflicts, may result in disciplinary action up to, and/or including, immediate termination of employment.

StayWell Independent contractors

Independent contractors - who medically review health content for SCHL and Krames CHL - must avoid situations that create an actual or potential conflict of interest between personal interests and StayWell's interests in presenting fair, impartial and credible articles.

Potential conflicts of interest include:

Having a direct or indirect financial interest in or relationship with a source or some other third party that may be affected by an article the writer is preparing. Such interests might include employment, consultancies or stock ownership (in excess of $10,000) in a health care or pharmaceutical firm, trade group or organization. This may include the financial interests of a spouse or a child.

Accepting personal gifts, entertainment, accommodation, transportation, or other services or items of value from sources or potential sources.

Not all such situations may pose a conflict. Independent contractors should disclose any potential conflicts to StayWell, even if they are not sure they constitute a conflict. Difficult cases may be referred to StayWell Legal Counsel for guidance. Independent contractors who have separate relationships with health care, trade or pharmaceutical organizations should disclose this to StayWell before they work for StayWell.

For background information on our medical reviewers, authors and editor, please review Digital Health Content Reviewers for StayWell or Krames Consumer Health Library.

Questions about policies

Consumers can email questions about our policies to [email protected].

We respond to clients within 24 hours on business days.

General Inquiries or Information

Please email us at [email protected] or call 877-330-3796 and select Option #1.

Reviewed and Approved by the Quality Oversight Committee: Q4 2022

Revised: March 2024