UPMC requires key employed and nonemployed personnel to comply with its Conflict of Interest Policies when they engage in UPMC-related business. People covered by the policies include:
These people are required to complete a questionnaire at least annually, which along with other data is used to identify possible individual and institutional conflicts of interest. If a potential conflict is identified regarding a specific UPMC activity, the Corporate Compliance Department, with the assistance of the Legal Department, helps to develop a written plan designed to prevent the conflict from influencing decisions related to that activity. The process is ultimately overseen by a Conflict of Interest Committee of the Board of Directors.