OCI Management Plan – Haima Therapeutics LLC

 

This plan details the ways in which Haima Therapeutics LLC (“Haima”), its employee, consultants and representatives identify, manage, prevent and mitigate potential Organizational Conflicts of Interest (OCI) relating to commercial and government related programs.  The plan will serve as a general guideline for all Haima projects.

 

Organization Conflicts of Interest Per FAR 9.5 Requirements

Haima is aware of the U.S. Government’s concern for OCIs as applied to procurement. Haima has not provided services or prepared specifications for the any office of the US Government or gained access to proprietary information from any office of the US Government which could result in an unfair competitive advantage.

Organization Conflicts of Interest Policy

1.     OCI Identification

a.     Identification.  The first step to managing OCIs is to identify that they may exist. The identification of potential OCIs will be done at two levels

                                      i.     Lead initiation:  As a part of evaluating potential partnership or collaboration opportunities, the Haima business development team will include, as part of its regularly scheduled meetings, the agenda item to identify and discuss potential OCI relating to each potential opportunity.  A key part of this review will include the identification of potential OCI.

                                    ii.     Ongoing OCI identification.  As projects mature, each project or program manager will be tasked with identifying potential OCI as a part of their program management duties.

2.     OCI Management

a.     Reporting: On identification of a potential OCI, management will work with the team members associated with the specific projects affected to create an OCI report and mitigation plan (template shown in exhibit I).  This plan must be approved by management and will include action items that could be performed immediately (i.e. actions don’t have to wait for the quarterly meeting).

3.     OCI Mitigations

a.     The OCI mitigations to be implemented may vary depending on the project and OCI.   Typical approaches to OCI mitigation to be practiced by Haima are listed below and can be referenced by type in an individual OCI report:

 

Firewall:  This approach to OCI mitigation insulates the team members performing on a project from any other projects that might create an OCI.  Creating a firewall within Haima may include the following:

  • A specific Haima team is assigned. No member from the project may perform on any other project where an OCI exists.

  • All non-public information relating to the project is kept confidential and only disclosed on an as-needed basis to the members supporting the specific project.  Information will be protected in the same fashion as Haima company confidential information is protected. The information will also be protected from other Haima employees not involved in the given project.

Non-Disclosure:  All Haima employees must execute an agreement that contains all of the necessary non-disclosure provisions to adequately protect the confidential information of collaborators and partners.

Disclosure:  In cases where potential OCI may exist, Haima will notify the potential and/or existing collaborators or partners affected and identify the potential OCI.  As appropriate, Haima will make the OCI mitigation plan available to the client(s) and gain their approval to proceed with full knowledge of the potential OCI.  No confidential information will be disclosed as a part of this mitigation approach.

 

4.     Haima Employee and Representatives

All Haima employees and consultants will receive and execute this OCI Management Plan prior to engagement on future projects.  Violation of this plan or improper disclosure of information will subject employee or consultants to disciplinary action and/or termination of their employment or consulting agreement.  Further legal action may also be pursued as required to ensure the protection of third party confidential information and recover any distributed funds resulting from the OCI.