Securities and Exchange Commission
Investor Advisory Committee Recusal Policy (DRAFT)
- The integrity of Committee deliberations is critical to the quality of discussions, member candor, and ultimately the objectivity of recommendations to the Commission. To ensure this integrity, a Committee member shall refrain from voting on matters that the Committee member believes may pose a conflict of interest in relation to his or her employment, business, or other personal concerns.
- A conflict of interest exists if employment, business, financial or other personal considerations may compromise a Committee member’s ability to objectively express his or her opinions regarding what investors in the U.S. capital markets need, want or should either be provided or protected from (hereafter referred to as “investor interests”). A conflict of interest does not exist simply because different Committee members have different views about investor interests, or have views which represent differences between different types of investors (e.g., individuals vs. institutions).
- Preserving the integrity of Committee deliberations is the responsibility of all Committee members. Any Committee member may ask another member to explain the basis for his or her opinions, representations or conclusions, and to articulate why and how these views support investor interests. The Committee recognizes and embraces the need for candor in this area, and commits to both presenting and receiving any such inquiry in the spirit of openness and collegiality.