IBLCE CONFLICT OF INTEREST POLICY

Approved: September 24, 2011 by the IBLCE Board of Directors

Supersedes: March 26, 2011

Purpose: Members of the International Board of Lactation Consultant Examiners (IBLCE)

must conduct their personal and professional affairs in such a manner as to avoid any possible
conflict of interest with their duties and responsibilities to IBLCE. They are required to exercise
their responsibilities in the interest of IBLCE, not in their own interest, the interests of the
constituency selecting them, or the interest of any other entity or person.

The IBLCE Conflict of Interest Policy is not designed to eliminate relationships and activities
that may create a duality of interest. It is to require and ensure the disclosure of any conflicts of
interest and the recusal of any interested party in a decision relating thereto.

The IBLCE Conflict of Interest Policy shall apply to all Members of IBLCE (as the same are
defined below) be signed by all members of IBLCE upon beginning IBLCE work and annually
during the first Board meeting of the calendar year.

Definitions:
1. “Members of IBLCE” as used herein shall mean members of the IBLCE Board of Directors,
IBLCE Committee Members, IBLCE Staff members, IBLCE Contractors and their Affiliated
Persons.

2. “Affiliated Persons” as used herein shall mean persons who are first or second degree
relatives by blood, adoption or marriage, are business affiliates of, or are subordinate to
Members of IBLCE, and any persons acting on behalf of any such Affiliated Persons, unless
otherwise expressly stated herein.

3. "Financial Interests" as used herein shall mean any position as owner, officer, Board
member, director, trustee, partner, or joint venturer, member of a limited liability company,
stockholder, employee, contractor, agent or other beneficiary. A potential conflict of interest
arises when a Member of IBLCE holds a financial interest in or may be affected financially
IBLCE Conflict of Interest Policy Page 1 of 8
Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
 (either positively or adversely), directly or indirectly, as the result of IBLCE procedures,
policies, resolutions, purchases (of services, materials or supplies), other IBLCE action, or
deliberate inaction by IBLCE.

4. "Professional Interests" as used herein shall mean any affiliation with or relationship to any
person, institution, organization or other entity which is involved with infant feeding
products or infant feeding issues in any way. A potential conflict of interest arises when a
Member of IBLCE holds a professional interests or may be affected professionally (either
positively or adversely), directly or indirectly, as the result of IBLCE procedures, policies,
resolutions, purchases (of services, materials or supplies), other IBLCE action, or deliberate
inaction by IBLCE.

Policy:
An actual or potential conflict of interest occurs when a Member of IBLCE is in a position to
influence a decision that may result in personal gain or gain for a relative or other affiliated
person as a result of the work of IBLCE. It is acknowledged that Members of IBLCE may have
interests in conflict with those of IBLCE. These are not inherently illegal nor are they to be
regarded as a reflection upon the integrity of either IBLCE or the person with the possible
conflict. It is the manner in which such conflicts are handled which determines the propriety of
the transaction. No presumption of a conflict is created by the mere existence of a relationship
with outside organizations.

The following principles guide IBLCE: (1) awareness; (2) annual written disclosure; (3)
disclosure of conflicts arising in individual and episodic situations; and (4) disinterested review.
This includes not counting conflicted persons when determining the quorum for the meeting, and
that the conflicted persons not vote or use personal influence with regard to the matter being
discussed.

• IBLCE Bylaws. The IBLCE Bylaws were amended on March 21, 2009, to provide as
follows:
ARTICLE IX
Conflicts of Interest

All individuals connected to the IBLCE shall protect the interests of the IBLCE.
The existence, nature and extent of any possible conflict of interest on the part of a
Member of the IBLCE Board of Directors, a Member of an IBLCE Committee, or an
IBLCE Staff Person or Contractor shall promptly be disclosed in writing, and made a
matter of record. Directors and Committee Members having a possible conflict of interest
regarding a matter of concern to the IBLCE and shall recuse his/herself on the matter.
The minutes of the meeting shall reflect that these requirements were met.

This policy shall also apply to the immediate family and any person acting on
behalf of an IBLCE director, committee member, staff member.
IBLCE Conflict of Interest Policy Page 2 of 8
Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
• Use of IBLCE Resources, including Services, Property or Facilities. A Member of
IBLCE should not use IBLCE resources while engaging in any outside employment or any
other outside activity. A Member of IBLCE should not engage in any outside employment or
any other outside activity which competes with or is otherwise adverse to the interests of
IBLCE, or which might reasonably imply IBLCE sponsorship or support of such
employment or activity.

• IBLCE Information. A Member of IBLCE must never use any information received while
serving with IBLCE, if the personal use of such information would be detrimental in any way
to IBLCE. Any actions that might impair the reputation of IBLCE must also be avoided.

• Intellectual Property, including Examination Items. A Member of IBLCE may not

disclose information about the content of the IBLCE examination unless that information is
already known by the public or is of public record. Disclosure of any examination items is
strictly prohibited. All IBLCE intellectual property, including examination content must be
treated as confidential information.

• Confidential Information. A Member of IBLCE should not, in the regular course of

business, disclose information about the corporation's legitimate activities unless they are
already known by the public or are of public record. All information disclosed at Board
Meetings, Committee Meetings or Staff Meetings, or disseminated between such meetings,
should be kept strictly confidential. Disclosure to the public of corporate activities should be
made only through IBLCE's officially designated spokespersons, the Chair of the Board and
the Executive Director.

• Disclosure of a Conflict of Interest. This Conflict of Interest Policy will be disseminated

annually to all Members of IBLCE. The Conflict of Interest Disclosure Statement shall be
completed and signed by each staff and board Member of IBLCE as well as contractors. Any
disclosures that arise should be brought to the attention of the Audit Committee.

• Procedures for Addressing a Conflict of Interest.

1. Conflict of interest disclosures involving IBLCE Board Directors or Committee members
should be made to the Audit Committee.

2. Conflict of interest disclosures involving a Staff Member (whether an employee or

contractor) should be made to the Audit Committee, Executive Director and his/her direct
supervisor. If the Executive Director is the one with the conflict, then the disclosure
should be made to the Audit and Executive Committees.

3. The Audit Committee shall determine if the allegation(s) would constitute a material
conflict. If no material conflict is found, the matter shall be dismissed. If a material
IBLCE Conflict of Interest Policy Page 3 of 8
Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
 conflict is found, the Committee or designees shall investigate the claim. In all cases, the
Audit Committee will apprise the Board of Directors of the conflict of interest allegation.

4. After exercising due diligence by the Audit Committee and/or Executive Director and/or
other persons with specialized knowledge, the Board shall determine whether the
organization can obtain with reasonable efforts, a more advantageous transaction or
arrangement from a person or entity that would not give rise to a conflict of interest.

5. If a more advantageous transaction or arrangement is not reasonably possible under

circumstances not producing a conflict of interest, the Board shall determine by a
majority vote of the disinterested Directors whether the transaction or arrangement is in
the organization’s best interest, for its own benefit, and whether it is fair and reasonable.
In conformity with the above determination, it shall make its decision as to whether to
enter into the transaction or arrangement.

• Steps for a Conflict of Interest Violation. If a Member of IBLCE violates this Conflict of
Interest Policy, IBLCE will take one of the following steps of action:

1. Counsel the Member of IBLCE about the violation

2. Reprimand the Member of IBLCE

3. Request that the Member of IBLCE resign

4. Remove the Member of IBLCE from the Board or terminate employment/contract

IBLCE Conflict of Interest Policy Page 4 of 8

Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
International Board of Lactation Consultant Examiners (IBLCE)

Conflict of Interest Policy for IBLCE members Teaching Lactation

Approved: By Audit Committee August 2015, approved by Board September 2015.

Purpose: This Conflict of Interest Policy specifically relates to International Board of Lactation
Consultant Examiners (IBLCE) members who are involved in teaching lactation on designated
programs leading to eligibility for IBLCE examination. This policy will be enacted as an
addendum to the existing IBLCE Conflict of Interest Policy as detailed below.

Extract for COI Policy

• Members of the IBLCE must conduct their personal and professional affairs in such a
manner as to avoid any possible conflict of interest with their duties and responsibilities
to IBLCE. They are required to exercise their responsibilities in the interest of IBLCE,
not in their own interest, the interests of the constituency selecting them, or the interest of
any other entity or person.
• The current IBLCE Conflict of Interest Policy is not designed to eliminate relationships
and activities that may create a duality of interest. It is to require and ensure the
disclosure of any conflicts of interest and the recusal of any interested party in a decision
relating thereto.
• This Policy applies to all Members of IBLCE (as the same are defined below), be signed
by all members of IBLCE upon beginning IBLCE work and annually during the first
Board meeting of the calendar year.

Definition:
1. Pathway programs relate to those leading to eligibility for IBLCE examination. At present this
relates to Pathway 2.

Policy:
An actual or potential conflict of interest occurs when a Member of IBLCE is involved in
teaching Lactation sessions on a pathway program leading to eligibility for the IBLCE
examination. The IBLCE member is required to declare this to the IBLCE on the annual COI
declaration.

When this is declared then the IBLCE member will be:

• Ineligible for appointment to the IBLCE Examination Committee;
IBLCE Conflict of Interest Policy Page 5 of 8
Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
 • Ineligible to vote on any IBLCE related Pathway program issues.

In the event of violation then the action will be in line with the existing IBLCE Conflict of
Interest Policy as below:

• Possible steps of actions for a Conflict of Interest Violation. If a Member of IBLCE

violates this Conflict of Interest Policy, IBLCE will take one of the following steps of
action:
1. Counsel the Member of IBLCE about the violation
2. Reprimand the Member of IBLCE
3. Request that the Member of IBLCE resign
4. Remove the Member of IBLCE from the Board or terminate employment/contract

IBLCE Conflict of Interest Policy Page 6 of 8

Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
International Board of Lactation Consultant Examiners (IBLCE)

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved: By Audit Committee August 2015, approved by Board September 2015.

Purpose: This Conflict of Interest Policy specifically relates to International Board of Lactation
Consultant Examiners (IBLCE) members who act in the capacity as Mentor on programs leading
to eligibility for IBLCE examination. This policy will be enacted as an addendum to the existing
IBLCE Conflict of Interest Policy as detailed below.

Extract for COI Policy

• Members of the IBLCE must conduct their personal and professional affairs in such a
manner as to avoid any possible conflict of interest with their duties and responsibilities
to IBLCE. They are required to exercise their responsibilities in the interest of IBLCE,
not in their own interest, the interests of the constituency selecting them, or the interest of
any other entity or person.
• The current IBLCE Conflict of Interest Policy is not designed to eliminate relationships
and activities that may create a duality of interest. It is to require and ensure the
disclosure of any conflicts of interest and the recusal of any interested party in a decision
relating thereto.
• This Policy applies to all Members of IBLCE (as the same are defined below), be signed
by all members of IBLCE upon beginning IBLCE work and annually during the first
Board meeting of the calendar year.

Definitions:

1. Mentor is an individual who meets the criteria of being a certified IBCLC Certificant. This
policy relates to Mentors who are currently appointed as members of the IBLCE.
2. Pathways relate to programs where the applicant completes a period of clinical practice under
supervision of a mentor with this program leading to eligibility for the IBLCE examination. At
present this relates to Pathway 3.

Policy:

An actual or potential conflict of interest occurs when a Member of IBLCE is appointed as

mentor to an applicant on a Pathway program leading to eligibility for the IBLCE examination.
The IBLCE member is required to declare this to the IBLCE on the annual COI declaration.
IBLCE Conflict of Interest Policy Page 7 of 8
Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015
When this is declared then the IBLCE member will be:

• Ineligible for appointment to the IBLCE Examination Committee;

• Ineligible to vote on any IBLCE related Pathway issues.

In the event of violation then the action will be in line with the existing IBLCE Conflict of
Interest Policy as below:

• Possible steps of action for a Conflict of Interest Violation. If a Member of IBLCE

violates this Conflict of Interest Policy, IBLCE will take one of the following steps of
action:
1. Counsel the Member of IBLCE about the violation
2. Reprimand the Member of IBLCE
3. Request that the Member of IBLCE resign
4. Remove the Member of IBLCE from the Board or terminate employment/contract

IBLCE Conflict of Interest Policy Page 8 of 8

Approved September 24, 2011

Addendum: Conflict of Interest Policy for IBLCE Members Teaching Lactation

Approved September 2015

Conflict of Interest Policy for IBLCE members appointed as Mentors

Approved September 2015