Conflicts of interest
Independence, stated plainly.
Conflicts are inevitable in a small industry. What matters is whether they are declared, recorded and managed before they touch a decision.
- Standards
- v0.9 — Pilot draft
- Status
- Published
- Review cycle
- Reviewed quarterly

Certification is granted for a defined scope and remains subject to monitoring.
- Standards version
- v0.9 — Pilot draft
- Decision basis
- Published criteria
- Independence
- Commercial roles excluded
- Change control
- Dated effective versions
Declarations
What must be declared.
- Employment, consulting or advisory relationships with an applicant
- Equity, options or revenue interests in an applicant or competitor
- Family or household relationships with applicant leadership
- Prior involvement in building the workflow under review
- Any arrangement that could reasonably appear to affect judgment
Management
How declared conflicts are handled.
- 1
Recusal
The conflicted individual is removed from the review, decision and appeal for that applicant.
- 2
Reassignment
The matter is assigned to a reviewer with no declared relationship.
- 3
Recording
The declaration and the action taken are recorded in the decision file.
- 4
Periodic review
Declarations are refreshed at defined intervals and on any material change.
Program level
Partners and investors do not receive preferential treatment.
Commercial relationships with processors, banks, platforms, pharmacies or investors do not alter certification criteria, findings or outcomes for any business.
Where a partner relationship exists with an applicant, it is disclosed in the decision record.
Not sure where your organization stands? Start with a preliminary eligibility check.
Compliance should be clear, not complicated
Start with a clearer view of your compliance readiness.
Check your eligibility, define your review scope, and see how ScriptClear can help organize the path from initial assessment to continuous monitoring.
Know where you stand. Fix what matters. Stay ready.
