Instructions for Use

Use this template to document a conflict of interest management plan. POL-009 (Conflicts of Interest), Section 5.0, Step 5, requires the Compliance Officer to document a written management plan whenever a disclosed conflict is determined to exist, stating the restriction applied. This template satisfies that requirement when completed in full and signed.

How to use this template:

1. The Compliance Officer prepares the plan after determining, from a disclosure (CFM-002), that a conflict exists.
2. Complete one plan per conflict. Record the source disclosure-log entry (CFM-004) so the plan links back to the disclosure it resolves.
3. Describe the conflict plainly: what it is, who is involved, and which ABAS decisions or duties it affects.
4. State the restriction applied. POL-009 Section 5.0 Step 5 names recusal, reassignment of the decision, divestiture, and limits on outside work; select the restriction or combination that resolves the conflict, and describe how it will be carried out.
5. The employee and their supervisor both sign the plan, acknowledging the restriction and their responsibility to comply with it.
6. If a conflict cannot be resolved by a management plan, it is escalated to the Executive Director under POL-009, Section 5.2. Where the Executive Director is involved, it is escalated to the Compliance Committee instead.

Form Realization and Fallback

This is the canonical, authoritative version of Form CFM-003, maintained in the compliance documentation. It defines the fields, sections, and structure that any realization of the form must capture.

ABAS may complete this plan through an electronic realization: a web form, a tablet form, or direct electronic submission to company files. Any electronic realization must capture the same content and carry the form identifier CFM-003, so the policy and SOP refer to the form by its identifier rather than to any one channel.

The documented form here is always available as a fallback. It can be printed and completed on paper whenever an electronic form is unavailable or a paper form is otherwise needed, for example during a system outage or a loss of internet access.

Alternate-language and electronically read (screen-reader) versions are derived from this canonical form and must match it, so the same content stays authoritative across every realization.

Management Plan Template

Plan Information

Part 1: Description of the Conflict

State what the conflict is, who is involved, and which ABAS decisions, duties, or relationships it affects. Identify the POL-009 category it falls under.

POL-009 category: ☐ 5.3 Outside employment / private ABA work ☐ 5.4 Financial interest in a vendor or referral source ☐ 5.5 Family or personal relationship ☐ 5.6 Gifts ☐ Other

Description:

Part 2: Restriction Applied

Select the restriction or combination that resolves the conflict, and describe how it will be carried out in practice (who does what, and from what date).

• ☐ Recusal. The employee steps back from the conflicted matter and takes no part in the related decision.
• ☐ Reassignment of the decision. The affected decision is reassigned to another qualified employee, named below.
• ☐ Divestiture. The employee or family member ends the financial interest that creates the conflict.
• ☐ Limits on outside work. Specific limits are placed on the outside employment or activity.
• ☐ Other. Describe.

How the restriction will be carried out:

Where a decision is reassigned, name the qualified employee who will assume it:

Effective date of the restriction:

Part 3: Monitoring and Review

Signatures

By signing, the employee and supervisor acknowledge the conflict, the restriction applied, and their responsibility to comply with this plan.

Form CFM-003 · Owning policy: POL-009 (Conflicts of Interest). Version number and effective date are set in ABAS's document-control record at adoption.

Retention

Completed management plans are part of the compliance program files. Per POL-009, Section 5.0, Step 6:

• The Compliance Officer retains each management plan in the compliance program files, together with the disclosure that prompted it (CFM-002).
• The plan is linked to its entry in the Conflict of Interest Disclosure Log (CFM-004), and the log tracks the plan's status.
• Management plans are reviewed at least at the annual disclosure cycle and updated when circumstances change.

The Compliance Officer is custodian of management plans and maintains them at a company-owned level, consistent with the compliance program's records practices.