Tab 14: Conflict of Interest Policy and Disclosures
The community foundation submits a board-approved conflict of interest policy that covers all aspects of its operations and applies to board, staff, and standing board committee members.
Material Changes: For the purposes of reconfirmation, a material change is any change in the policy or disclosure procedures which changes the types of conflicts that must be disclosed, the procedures for handling conflicts of interest or the documentation procedure for conflicts of interest.
For more information, review Core materials, FAQs and a glossary of important terms
Related Standards
II. Mission, Structure and Governance
II.F.3 A community foundation's governing body approves and monitors policies regulating the ethical operations of the community foundation.
Key Elements
- Policies to prevent perceived, potential, and actual conflicts (Policy must apply to all aspects of community foundation operations. Policies that apply solely to grantmaking or investments, for instance, or any discrete portion of operations, do not meet the related standard.)
- Application of policies to all of the following:
- board members
- staff members
- individuals serving on standing board committees (This is any volunteer that serves on a committee of the board but is not serving on the board)
- Procedures for handling disclosures of conflicts
- Evidence of disclosures of conflicts of interest are provided for the following:
- board members
- staff members
- individuals serving on standing board committees (This is any volunteer that serves on a committee of the board but is not serving on the board)
- Evidence that conflicts of interest policies are followed
Suggested Documents
- Samples of redacted statements for each group
- Corporate records or minutes with highlighted sections noting board members’ disclosures of conflicts with regard to grants or business affairs
- Copy of policy
- Signed conflicts of interest provision of the employee handbook
Should my submitted conflicts of interest documents be signed?
The samples of redacted statements for each group should be signed. The reviewer cannot verify that the policy is in effect if there are no signed statements. Additionally, if the corporate records or minutes are submitted they should be highlighted to indicate where board members have disclosed conflicts of interest.
How does the conflict of interest policy apply to all aspects of community foundation operations?
The conflict-of-interest policy should cover not only grantmaking but other issues such as financial issues such as choosing vendors.
What if my foundation does not have volunteers serving on standing committees of the board?
If you do not have non-board-member volunteers serving on committees, you may submit a signed statement to that effect. If you currently do not have volunteers serving on committees but anticipate that you may have volunteers serving on committees in the future, please show that the written policy will apply to them.
A member of a governing board.
Reconfirming?
Review all key elements and consider if your organization has made changes to your policies, powers or practices.
Pay special attention to key elements and core materials marked with ![[R icon]](/images/icon_reconfirm_body.gif){kind=icon}
and a ![[P icon]](/images/icon_pension_body.gif){kind=icon}
. These represent minimum requirements for reconfirmation as well as Pension Protection Act requirements. Items marked with a are particularly critical for those who submitted record books prior to January 2007.
Document your compliance with each of these items as well as with all other key elements where support materials may have changed.
Sample Documents
COI Statement, Berkshire Taconic Community Foundation (submitted 2005)
COI Policy, The Boston Foundation (submitted 2005)
COI Disclosure, Community Foundation of Greater Lorain (submitted 2005)
COI Policy, The Greater Greenville Community Foundation (submitted 2008)
COI Policy, Yakima Valley Community Foundation (submitted 2008)