Purpose
The purpose of this policy is to provide guidance to employees, board members, and volunteers of both Safe Families and 1000 Generations regarding situations that may generate a real or perceived conflict of interest.
Scope
This policy applies to all employees, board members, and volunteers of both Safe Families and 1000 Generations.
Definitions
A conflict of interest occurs when an individual’s obligation to further the organization’s charitable purposes is at odds with their own financial interests. For example, a conflict of interest would occur when an officer, director, or trustee votes on a contract between the organization and a business that is owned by the officer, director, or trustee. Conflicts of interest frequently arise when setting compensation or benefits for officers, directors, or trustees.
Duty to Disclose
Employees, board members, and volunteers of both Safe Families and 1000 Generations must disclose any actual or potential conflicts of interest to the organization's leadership.
Review of Disclosure
The organization's leadership will review all disclosures to determine whether a conflict of interest exists and, if so, whether it can be managed or eliminated.
Prohibition on Self-Dealing
Employees, board members, and volunteers of both Safe Families and 1000 Generations are prohibited from engaging in any transaction that results in personal gain or benefit to the individual at the expense of the organization.
Annual Disclosure
All staff directors and board members of both Safe Families WI and 1000 Generations must submit an annual disclosure statement identifying any actual or potential conflicts of interest.
Record Keeping
The organization will maintain records of all disclosures and actions taken to manage or eliminate conflicts of interest.
Areas In Which Conflict May Arise
Conflicts of interest may arise in the relationships of directors, officers, and management employees with any of the following third parties:
- Persons and firms supplying goods and services to the organization
- Persons and firms from whom the organization leases property and equipment
- Persons and firms with whom the organization is dealing or planning to deal in connection with the gift, purchase, or sale of real estate, securities, or other property
- Having a financial or other interest in the assets, leases, business transactions, or professional services of the organization
- Accepting favors, gifts, gratuities, or taking part in any activities or transactions that relate to, affect, or influence decisions made for, regarding, or on behalf of the organization
- Using donor information or relationships inappropriately or in ways that might damage donor confidentiality and/or relationships with the organization
- Steering or accepting referrals of applicants or persons served to a private practice in which employees, consultants, or the immediate families of employees or consultants are engaged
- Low interest or forgiveness of personal loans made by the organization to covered persons
- Preferential treatment of covered persons when applying for and receiving the organization’s services
- Competing or affinity organizations
- Donors and others supporting the organization
- Agencies, organizations, and associations which affect the operations of the organization
- Nepotism -- family members, friends, and other employees
Interpretation of this Policy
The areas of conflicting interest listed above, and the relations in those areas which may give rise to conflict, are not exhaustive. Conflicts might arise in other areas or through other relations.
It is assumed that the directors, officers, and management employees will recognize such areas and relation by analogy.
Disclosure Policy and Procedure
Transactions with parties with whom a conflicting interest exists may be undertaken only if all of the following are observed:
- The conflicting interest is fully disclosed
- The person with the conflict of interest is excluded from the discussion and approval of such transaction
- A competitive bid or comparable valuation exists
- The board or a duly constituted committee thereof has determined that the transaction is in the best interest of the organization
Disclosure in the organization should be made to the Chief Executive Officer (or if she or he is the one with the conflict, then to the Board Chair), who shall bring the matter to the attention of the Board or a duly constituted committee thereof. Disclosure involving directors should be made to the Board Chair, (or if she or he is the one with the conflict, then to the Board Vice-Chair) who shall bring these matters to the Board or a duly constituted committee thereof.
The Board or a duly constituted committee thereof shall determine whether a conflict exists and in the case of an existing conflict, whether the contemplated transaction may be authorized as just, fair, and reasonable to the organization. The decision of the Board or a duly constituted committee thereof on these matters will rest in their sole discretion, and their concern must be the welfare of the organization and the advancement of its purpose.
Responsible Party
The State Director is responsible for the administration of this policy, at the direction of the Secretary and Board of Directors.
Conclusion
Both Safe Families and 1000 Generations are committed to upholding the highest standards of integrity, transparency, and accountability. The Conflict of Interest Policy is an important tool in ensuring that the organizations' operations are conducted in an ethical and responsible manner. This policy will be reviewed and updated annually to ensure that it remains current with any changes in applicable laws and regulations.