USB Policy requires an annual Conflict of Interest Disclosure Statement completed by employees, contractors and subcontractors. It is the responsibility of USB’s Primary Contractors to maintain all completed employee and subcontractor conflict of interest disclosure statements engaged in USB business on an annual basis. Primary Contractors will provide completed Conflict of Interest Disclosure Statements to USB upon request and will include a Conflict of Interest provision in each Primary Contractor and subcontractor agreement.
- Responsible Person- Each Subcontractor must appoint one person to act as the responsible person to ensure compliance with the USB Conflicts of Interest Policy. This person must either be the person authorized to sign the Agreement or the principle investigator. The responsible person is responsible for:
- Making reasonable efforts to identify conflicts of interest.
- Completing the USB Conflicts of Interest Form.
- Delivering a copy of the USB Conflicts of Interest Form to the USB Primary Contractor.
- Number of Forms- Each Subcontractor is only required to complete one form for the entire institution. This form should contain any information collected from that institution
- Actual Knowledge Only- Each Subcontractor is only required to disclose any conflicts of interest that the responsible person has actual knowledge of at the time the USB Conflicts of Interest Form is completed.
- Optional Investigation- While USB appreciates any effort by a Subcontractor to seek out potential conflicts of interest, USB does not expect the Subcontractor to perform any investigation of potential conflicts of interest before completing the USB Conflicts of Interest form.
- No Conflict Discovered- If the responsible person determines that there is no conflict of interest, the responsible person is not required to submit a completed form to the USB Primary Contractor.
- Updates and Corrections- In the event that a Subcontractor becomes aware of a conflict of interest after the submission of the USB Conflicts of Interest Form, the Subcontractor is requested to contact the Primary Contractor to disclose this information.
UNITED SOYBEAN BOARD SUBCONTRACTOR CONFLICT OF INTEREST DISCLOSURE STATEMENT I, ________________________________, a representative of a subcontractor of the United Soybean Board (the Board), have received, read and understand the Board’s Conflict of Interest and Gift Policy. _______ To the best of my knowledge, the subcontractor does not have a relationship with organizations/persons, who also have a relationship with the Board, that may give rise to a conflict of interest. _______ To the best of my knowledge, the subcontractor has a relationship with organizations/persons that may give rise to a conflict of interest. Please identify below the organization/person, the nature of the relationship and the nature of the transaction. Attach additional sheets if necessary. ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ Please list all gifts valued at more than $50 that any person at the subcontractor has received in the past year from organizations/persons who have transacted, are transacting, or may transact business with the Board. Attach additional sheets if necessary. ______________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ Please identify all travel-related benefits that any person at the subcontractor has received in the past year from organization/persons who have transacted, are transacting, or may transact business with the Board. Attach additional sheets if necessary. ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ I understand that if a conflict of interest does arise after this disclosure, that I will immediately report it to the USB Executive Director or CEO.
Subcontractor’s Representative’s Signature