Here is a sample template for a Conflict of Interest Policy:
[Your Organization’s Name] Conflict of Interest Policy
1. Purpose: The purpose of this Conflict of Interest Policy is to establish a framework for identifying, disclosing, and managing conflicts of interest that may arise among board members, officers, employees, volunteers, and any other individuals associated with [Your Organization’s Name].
2. Definitions:
Conflict of Interest: A conflict of interest exists when an individual’s personal, financial, or other interests or obligations may interfere with their ability to act in the best interests of [Your Organization’s Name].
Interested Party: An interested party refers to any individual who has a direct or indirect financial or personal interest in any transaction, decision, or activity involving [Your Organization’s Name].
3. Duty to Disclose:
All individuals associated with [Your Organization’s Name] have a duty to promptly and fully disclose any actual or potential conflicts of interest to the Board of Directors and the Executive Director, if applicable. Disclosure should be made in writing and should include all relevant details.
Disclosure should occur upon joining [Your Organization’s Name], annually thereafter, and whenever a new potential conflict arises.
4. Procedures for Review:
The Board of Directors shall appoint a Conflict of Interest Committee responsible for reviewing disclosures and potential conflicts of interest.
The Committee shall investigate, evaluate, and determine the appropriate response to conflicts of interest.
5. Recusal and Non-Participation:
Individuals with a conflict of interest shall recuse themselves from any discussion, deliberation, or voting related to the matter in question.
They shall not participate in any way that may compromise the objectivity and integrity of the decision-making process.
6. Decision and Documentation:
The Committee shall make recommendations to the Board of Directors on how to address conflicts of interest.
All decisions and actions taken to address conflicts of interest shall be documented in writing and maintained in the organization’s records.
7. Confidentiality:
All disclosures and discussions related to conflicts of interest shall be treated with strict confidentiality, except as required by law.
8. Annual Statements:
All individuals associated with [Your Organization’s Name] shall be required to submit an annual conflict of interest statement affirming their understanding and compliance with this policy.
9. Legal and Financial Counsel:
Individuals who have questions or concerns about potential conflicts of interest are encouraged to seek independent legal or financial counsel at their own expense.
10. Reporting to Authorities:
In cases where conflicts of interest may involve illegal or unethical conduct, [Your Organization’s Name] reserves the right to report such matters to relevant authorities.
11. Compliance and Consequences:
Failure to comply with this Conflict of Interest Policy may result in disciplinary action, including but not limited to suspension, termination, or removal from the organization.
12. Annual Review:
The Board of Directors shall review this policy annually and make updates as necessary.
13. Adoption and Acknowledgment:
I, the undersigned, have received, read, and understand [Your Organization’s Name]’s Conflict of Interest Policy. I agree to comply with its provisions and obligations.
Signature: _______________________________ Date: ____________