14: Conflict of Interest Policy and Disclosures

Confirming
Reconfirming

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.

Key Elements 
  1. 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.)
  2. 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)
  3. Procedures for handling disclosures of conflicts
  4. 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)
  5. Evidence that conflicts of interest policies are followed

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. If you have had material changes, you will need to resubmit any documentation related to material changes. Review all key elements for this requirement by clicking the "confirming" toggle in the upper left corner of this page.

Core Materials 

Required 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
No documents required for reconfirmation.

Suggested Documents

  • Signed conflicts of interest provision of the employee handbook