Policy on corporate relationships
SIR Foundation greatly values and relies upon financial support from reputable corporations to further its mission to advance the science and art of interventional radiology and promote community health, patient welfare, and public education in this medical field. In many instances, financial support from corporate entities enables SIR Foundation to engage in continuing medical education programs, public education initiatives and other activities that could not otherwise be pursued. The following guidelines were established to ensure that all of SIR Foundation's corporate support arrangements advance its mission and strategic goals, serve the best interests of the membership, retain SIR Foundation's independence and avoid conflicts of interest.
1. Definition of corporate arrangements. For the purpose of these guidelines, "corporate arrangements" shall mean transactions in which SIR Foundation receives funds or other contributions from a commercial organization, either as a direct donation in support of an SIR Foundation program or activity or as part of a collaborative public education program or event.
2. Consistency with SIR Foundation's mission. When appropriate and desirable, SIR Foundation may participate in corporate arrangements to support activities that will further SIR Foundation's mission of advancing interventional radiology through research and education. SIR Foundation shall exercise sole discretion in choosing its corporate sponsors.
3. Review and approval. Any proposed corporate arrangements, other than those involving just an unrestricted donation of funds, must be reviewed and approved by SIR Foundation's Board to ensure that such arrangements would have no potential influence on SIR Foundation policies, are consistent with SIR Foundation's mission and goals, do not pose a conflict of interest, and in no way affect the objectivity of the association, its members, activities and programs. SIR Foundation’s executive staff will review and approve prior to publication or dissemination all marketing materials bearing SIR Foundation's name, logo and/or other identifying information for compliance with these principles and guidelines.
4. No endorsement. Participation in a specific corporate arrangement should not in any way imply SIR Foundation's endorsement of that corporation's general policies, products or services, nor imply that SIR Foundation will exert any influence to advance the corporation's interests outside the substance of the arrangement itself. SIR Foundation's name, logo and/or identifying information may not be used in a manner that would express or imply SIR Foundation's endorsement of the corporation or its policies.
5. Written agreement. The terms, conditions, and purposes of the financial support will be documented by a signed agreement between the corporate supporter and SIR Foundation. In entering into a corporate agreement under this policy, SIR Foundation will ensure to the extent feasible that taxable and non-taxable payments are separately identified and itemized in the agreement.
6. No free advertising or return benefit. Corporate supporters will not be entitled to receive free advertising (as that term is defined by the Internal Revenue Code ("IRC") or Internal Revenue Service ("IRS") rules and regulations) or other substantial return benefit from its contribution other than appropriate acknowledgments, items of nominal value and/or the use of SIR Foundation's name and logo in materials promoting a supported activity or project. For the purposes of this policy, "nominal" shall be defined according to IRS regulations (i.e., less than two percent of the contribution or $74, whichever is less). SIR Foundation may, in its sole discretion, provide nonqualitative acknowledgments of a supporter's contributions in its regular periodicals; however, supporters will not be entitled to such acknowledgments as a condition of their contributions.
7. Acknowledgments. Consistent with the corporate sponsorship provisions of the federal tax laws, SIR Foundation may permit program materials and activities to include acknowledgments of financial and other support from organizations. Such acknowledgments may identify and describe the company's products or product lines in neutral terms and may include the supporter's name, logo, slogan, locations, telephone numbers or website addresses as long as such acknowledgments do not include (a) comparative or qualitative descriptions of the company's products, services or facilities; (b) price information or other indications of savings or value associated with the company's products or services; (c) a call to action; (d) an endorsement; or (e) an inducement to buy, sell or use the sponsor's product or service. Any such acknowledgments will be created, or subject to prior review and approval, by SIR Foundation.
8. No product promotion. Organizations may not be permitted to advertise, market or otherwise promote specific products and services in connection with their sponsorship of SIR Foundation-related programs and activities, but products or services may be listed or displayed in a nonqualitative manner.
9. No contingent payments. SIR Foundation will not enter into a corporate arrangement where the amount of payment by the corporation is contingent upon attendance at an event or other measures of public exposure.
10. Free items to members. SIR Foundation will carefully scrutinize any corporate arrangements that give an organization the right to provide something of value to SIR members or other physicians to ensure that the giveaway item or service is of nominal value and is not tied to the volume or value of physician purchases of the sponsor's products or services.
11. CME rules. SIR Foundation maintains complete control of the content and speakers at any sponsored activity or event. Commercial sponsors will not control the planning, content or execution of the activity. Commercial sponsors may not attempt to direct or influence the faculty or content of SIR Foundation programs, except that SIR Foundation may ask the sponsor for suggested speakers and reference materials. SIR Foundation will follow the Standards for Commercial Support of Continuing Medical Education of the Accreditation Council for Continuing Medical Education (ACCME), which are incorporated herein by reference and attachment.
12. SIR Foundation's authority. SIR Foundation must maintain final authority on all collaborative projects and corporate arrangements. Direct contact between a sponsoring company and an SIR Foundation member(s) regarding a collaborative program/activity between SIR Foundation and that company shall be made only as approved by SIR Foundation.
13. Reports. Reports on SIR Foundation corporate activities will be regularly presented to SIR Foundation's Board.
14. Exclusivity. Whenever possible and feasible, SIR Foundation shall seek funding for programs from a variety of sources. It is understood, however, that occasions may arise when support of a specific event, publication, or service from a single source is appropriate. SIR Foundation will exercise special caution so that in circumstances when single support is granted, SIR Foundation avoids conflicts of interest and guards against any perception of conflict of interest.
15. Indemnification/Insurance. Where appropriate, SIR Foundation will ensure that organizations agree to appropriate indemnification and hold harmless provisions to protect SIR Foundation and its officers, directors, employees, and agents against any liability that might arise out of the organizations' acts or omissions with respect to a particular arrangement, including but not limited to any acts or omissions relating to the marketing, sale, dissemination, and/or use of a corporate sponsor's products. SIR Foundation may also require corporate sponsors to add the society to the sponsors' liability insurance where appropriate.
16. Termination. SIR Foundation reserves the right to terminate any corporate arrangement if the sponsor or its representatives or agents engage in any conduct, including but not limited to product promotion activities, that would lead SIR Foundation to reasonably determine that its continued participation in the arrangement with a particular company would adversely affect the goodwill and reputation of SIR Foundation or its affiliates. In the event of any such termination, SIR Foundation will relinquish the sponsors' contribution and return all unused funds. Upon expiration or termination, no further use may be made by the sponsor of SIR Foundation's name without the written approval of SIR Foundation.
17. Oversight. SIR Foundation's Board is responsible for establishing the principles and guidelines governing SIR Foundation's relationships with corporations. SIR Foundation's executive director is responsible for day-to-day oversight of all corporate arrangements.
Approved by SIR Foundation Board of Directors, Nov. 11, 2008.