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Effective Date: July 12, 2026

The PNH & Aplastic Anemia Family Alliance (“PNHAA,” “we,” “our,” or “us”) is committed to conducting its affairs with honesty, integrity, transparency, and accountability. This Conflict of Interest Policy is intended to protect the interests of PNHAA by helping ensure that decisions are made solely in the best interests of the organization and the individuals and families we serve.

This policy applies to all members of the Board of Directors, officers, employees, volunteers, advisors, committee members, contractors, and any individual acting on behalf of PNHAA.

Purpose

The purpose of this policy is to:

  • Promote ethical decision-making.
  • Protect the integrity and reputation of PNHAA.
  • Ensure charitable assets are used solely to advance our mission.
  • Prevent actual, potential, or perceived conflicts of interest.
  • Comply with applicable federal and state nonprofit laws.

Definition of a Conflict of Interest

A conflict of interest exists when an individual’s personal, professional, financial, or family interests could improperly influence—or appear to influence—their judgment or decisions made on behalf of PNHAA.

Conflicts may be actual, potential, or perceived and should be disclosed whenever they arise.

Examples of Conflicts of Interest

Examples include, but are not limited to:

  • Receiving personal financial benefit from a decision made by PNHAA.
  • Awarding contracts to a business owned by a board member or family member.
  • Participating in grant decisions involving relatives or close friends.
  • Receiving gifts or favors intended to influence organizational decisions.
  • Using confidential organizational information for personal gain.
  • Representing competing interests that may conflict with PNHAA’s mission.
  • Participating in decisions involving an employer, business partner, or client.

Duty to Disclose

Individuals covered by this policy have an ongoing obligation to disclose any actual, potential, or perceived conflict of interest as soon as it becomes known.

Disclosures should be made before participating in any discussion or decision related to the matter.

Review of Conflicts

When a conflict is disclosed, the Board of Directors or designated committee will determine whether a conflict exists and what action is appropriate.

Actions may include:

  • Determining that no conflict exists.
  • Requesting additional information.
  • Requiring the individual to abstain from discussion or voting.
  • Assigning the matter to an independent decision-maker.
  • Taking any other action necessary to protect the interests of PNHAA.

Recusal

Any individual with a conflict of interest shall not participate in discussions, deliberations, recommendations, or votes relating to the matter giving rise to the conflict.

The individual may be asked to leave the meeting during discussion of the matter.

Financial Transactions

Any financial transaction involving a board member, officer, employee, volunteer, contractor, or related party must be:

  • Fair and reasonable.
  • In the best interests of PNHAA.
  • Approved by disinterested decision-makers.
  • Properly documented.
  • Compliant with applicable nonprofit laws.

Compensation

PNHAA recognizes that qualified individuals may be compensated for legitimate services provided to the organization.

Compensation shall:

  • Be reasonable.
  • Reflect fair market value for services performed.
  • Be approved by disinterested members of the Board.
  • Be documented in organizational records.

No individual may approve their own compensation.

Grant & Financial Assistance Decisions

Individuals involved in reviewing financial assistance applications must remain impartial.

No person may participate in reviewing or approving assistance for:

  • Themselves.
  • Immediate family members.
  • Close personal friends.
  • Business associates.
  • Any individual where impartiality could reasonably be questioned.

Donor & Sponsor Relationships

PNHAA values the generosity of donors, sponsors, and funding partners.

Financial support shall never influence:

  • Educational content.
  • Medical information.
  • Patient navigation services.
  • Grant eligibility.
  • Financial assistance decisions.
  • Organizational governance.

All sponsorship relationships should be transparent and consistent with PNHAA’s mission.

Healthcare & Pharmaceutical Relationships

PNHAA may collaborate with hospitals, healthcare providers, nonprofit organizations, pharmaceutical companies, and other organizations whose work aligns with our mission.

These relationships shall not influence the accuracy, objectivity, or independence of PNHAA’s educational content, patient support services, or financial assistance programs.

Gifts & Gratuities

Individuals acting on behalf of PNHAA should not solicit or accept gifts, favors, or other items of value that could reasonably be perceived as influencing organizational decisions.

Nominal gifts of insignificant value may be accepted where permitted by law and organizational policy.

Confidential Information

Individuals serving PNHAA must not use confidential organizational information, donor information, patient information, or financial information for personal benefit or the benefit of others.

Confidential information must continue to be protected even after an individual’s relationship with PNHAA ends.

Annual Disclosure

Board members, officers, and other designated individuals may be required to complete an annual Conflict of Interest Disclosure Statement identifying any known conflicts or affirming that none exist.

Individuals are responsible for updating their disclosures if circumstances change during the year.

Violations of This Policy

Failure to disclose a conflict of interest or comply with this policy may result in corrective action, including:

  • Removal from a decision-making process.
  • Termination of volunteer or employment status.
  • Removal from the Board of Directors, where permitted by applicable law and governing documents.
  • Other appropriate corrective measures.

Policy Administration

The Board of Directors is responsible for overseeing this policy and ensuring that conflicts are addressed fairly, consistently, and in the best interests of PNHAA.

Changes to This Policy

PNHAA reserves the right to amend this Conflict of Interest Policy at any time to reflect changes in law, organizational practices, or governance standards.

Revisions become effective upon publication on this website or adoption by the Board of Directors.

Contact Us

If you have questions regarding this Conflict of Interest Policy, please contact us.

PNH & Aplastic Anemia Family Alliance (PNHAA)
Website: https://pnhaa.org
Email: governance@pnhaa.org

Our Commitment

PNHAA is committed to earning and maintaining the trust of patients, families, donors, volunteers, sponsors, healthcare professionals, and the communities we serve. We believe transparency, ethical leadership, and accountability are essential to fulfilling our mission. Every decision made on behalf of PNHAA should reflect our commitment to integrity, fairness, and putting the needs of individuals and families affected by PNH and aplastic anemia first.