It is ICAST's policy that all employees avoid any conflict between their personal interests and those of ICAST. The purpose of this policy is to ensure that ICAST's honesty and integrity, and therefore its reputation, are not compromised. The fundamental principle guiding this policy is that no employee should have, or appear to have, personal interests or relationships that actually or potentially conflict with the best interests of ICAST.

While it is not possible to give an exhaustive list of situations that might involve violations of this policy, below are some concrete examples of conflicts that must be avoided.

1. Holding an interest in or accepting free or discounted goods from any organization that does, or is seeking to do, business with ICAST, by any employee who is in a position to directly or indirectly influence either ICAST's decision to do business, or the terms upon which business would be done with such organization.
2. Holding any interest in an organization that competes with ICAST.
3. Being employed by (including as a consultant) or serving on the board of any organization which does, or is seeking to do, business with ICAST or which competes with ICAST;
4. Profiting personally, e.g., through commissions, loans, expense reimbursements, or other payments, from any organization seeking to do business with ICAST.

5. A conflict of interest would also exist when a member of an ICAST employee's immediate family is involved in situations such as those above.

This policy is not intended to prohibit the acceptance of modest courtesies, openly given and accepted as part of the usual business amenities for example, occasional business-related meals or promotional items of nominal or minor value.

ICAST will ensure any potential COI is documented and approved if required and will adhere to the following steps:

• All ICAST employees who will be working under Federal and State government contracts such as DOE grants are considered project investigators and will be aware of the DOE Conflict of Interest, (COI), Policy, and will sign annually, a statement certifying that they have no conflict of interest.
• The principal investigator will review any disclosures of significant financial interests to determine if it is related to a project funded under this grant and if it is a conflict of interest.
• ICAST will submit updated disclosures within 30 days of discovering or acquiring new significant financial interest and any employee with a potential conflict of interest will be excluded from working on the awarded grant. If an employee fails to disclose a conflict they may be dismissed, depending on the circumstances at the discretion of the Officers of ICAST.
• All ICAST employees will be receiving training on our COI policy during the on-boarding process and annually. ICAST will maintain records related to COI disclosures and responses to such disclosures and submit timely FCOI disclosures with information outlined in Section (V)(b)(3) of the DOE Interim COI Policy.  ICAST will conduct a retrospective review and draft a mitigation report for FCOIs that were not disclosed by employees and/or reported to DOE in a timely manner, following the requirements noted in Section (V)(a)(3)(ii) of the DOE Interim COI Policy.

It is the employee's responsibility to report any actual or potential conflict that may exist between the employee (and the employee's immediate family) and ICAST.

Contact Us

If you have any questions or suggestions about our Conflict of Interest and Business Ethics Policy, do not hesitate to contact us.