Conflict of Interest Policy
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A conflict of interest arises when a Trustee, committee member, or employee involved in making a decision is in the position to benefit, directly or indirectly, from his or her dealings with the Foundation or a person conducting business with the Foundation.
Trustees, committee members, volunteers and employees of the Foundation should disclose to the Trustees the nature of their personal or family affiliations or involvements with any organization that seeks a grant, even though such affiliation may not give rise to an actual conflict of interest.
All Trustees, committee members and employees will:
- Avoid conflicts of interest, or the appearance of conflicts, between their personal interests and those of the Foundation when dealing with outside entities or individuals.
- Disclose real or apparent conflicts of interest to the Chairman of the Board of Trustees or the President of the Foundation.
- Refrain from participating in any decisions on matters that involve an actual conflict of interest or the appearance of such a conflict.
- Because of the nature of the relationship that OCCF has with donors, nonprofits and other organizations all information received is strictly confidential.
Before a staff, board or volunteer committee member begins his or her service with the Foundation, he or she shall file with the president of the Foundation a list of his or her principal business activities, as well as involvement with other charitable and business organizations, vendors or business interests, or with any other associations that might produce a conflict of interest.
In addition to the disclosure required by the previous paragraph, each member is under an obligation to the Foundation, to his or her fellow staff or volunteers, and to the community served by the Foundation to inform the Foundation of any position he or she holds or of any business or a vocational activity that may result in a possible conflict of interest or bias for or against a particular grantee, action or policy, at the time such grant, action or policy is under consideration by the board or any volunteer committee of the Foundation. Any duality or possible conflict of interest on the part of any member shall be disclosed to the chair of the board (in the case of volunteers) or the president (in the case of staff members) and made a matter of record as soon as the issue in question is raised and a possible conflict is known.
When the board, committee or staff is to decide upon an issue about which a member has an unavoidable conflict of interest, that member shall physically absent herself or himself without comment from not only the vote, but also from the deliberation, unless directly requested by the chair of the board or relevant committee to provide factual information or answer factual questions that may assist the board or committee in making a wise decision. In no case shall that member vote on such matter or attempt to exert personal influence in connection therewith.
Disclosure and abstention shall be recorded in the minutes of the meeting(s) at which the issue is discussed and decided.
This policy shall be circulated to all Trustees, Committee members and employees only when changes are made to policy. They will be asked to sign it, indicating their compliance with the policy. All individuals will be asked to complete and sign the conflict of interest disclosure statement annually. Requests for interpretations of potential conflicts can be made by referring the matter to the Chairman of the Board of Trustees or President of the Foundation for consideration by the entire board at its next meeting.
The Foundation shall not provide loans to employees, Trustees or other volunteers. Additionally, private inurement, excessive personal benefit and/or self-dealing are prohibited. Any infraction may result in IRS penalty.