Conflict of Interest Disclosure
It is the policy of Donate Life Northwest to address how issues of actual, potential and perceived conflicts of interest involving trustees, officers, and employees of Donate Life Northwest should be identified, disclosed and managed. This form is designed to identify and disclose known conflicts in an effort to properly manage them.
Conflict of Interest Policy
This Conflict of Interest Policy governs the activities of the board and staff of Donate Life Northwest. Questions about the policy should be directed to the Executive Director. It is the duty of all board members and staff to be aware of this policy, and to identify conflicts of interest and situations that may result in the appearance of a conflict and to disclose those situations/ conflicts/ or potential conflicts to (i) the employee’s supervisor (ii) the executive director, (iii) the Chair of the Board or (iv) the Compliance officer, or other designated person, as appropriate. This policy provides guidelines for identifying conflicts, disclosing conflicts and procedures to be followed to assist Donate Life Northwest manage conflicts of interest and situations that may result in the appearance of a conflict.
What is a conflict of interest?
A conflict of interest arises when a board member or staff member has a personal interest that conflicts with the interests of Donate Life Northwest or arise in situations where a board/staff member has divided loyalties (also known as a “duality of interest”). The former can result in situations that result in inappropriate financial gain to persons in authority at Donate Life Northwest which can lead to financial penalties and violations of IRS regulations. Similarly, situations or transactions arising out of a conflict of interest can result in either inappropriate financial gain or the appearance of a lack of integrity in Donate Life Northwest‘s decision-making process. Both results are damaging to Donate Life Northwest and are to be avoided.
- Example #1: A person in a position of authority over the Organization may benefit financially from a transaction between the Organization and the board/staff member; or others closely associated with the board/staff member may be affected financially. Family members, or their businesses, or other persons or the businesses of persons with whom the board/staff member is closely associated, could benefit from similar transactions.
- Example #2: A conflict of interest could be a direct or indirect financial interest such as those described above, or a personal interest such as the situation where a board member of Donate Life Northwest is also a board member of another nonprofit or for-profit entity in the community with which Donate Life Northwest collaborates or conducts business.
Who might be affected by this policy?
Typically persons who are affected by a conflict of interest policy are the Organization’s board members, officers, and senior staff. In some cases a major donor could also be in a conflict situation. Donate Life Northwest takes a broad view of conflicts and board/staff are urged to think of how a situation/transaction would appear to outside parties when identifying conflicts or possible conflicts of interest.
Disclosure of Conflicts
Board members and senior staff will annually disclose and promptly update any disclosures previously made to the Chairperson of the board on an Annual Conflict Disclosure Questionnaire form provided by the Organization that requests them to identify their interests that could give rise to conflicts of interest, such as a list of family members, substantial business or investment holdings, and other transactions or affiliations with businesses and other organizations or those of family members as well as other nonprofit organizations.
Board and staff are also urged to disclose conflicts as they arise as well as to disclose those situations that are evolving that may result in a conflict of interest. Advance disclosure must occur so that a determination may be made as to the appropriate plan of action to manage the conflict. Staff should disclose to their supervisor or Executive Director, and board members should disclose to the board/chairperson of the board as soon as the person with the conflict is aware of the conflict/potential conflict or the appearance of a conflict.
Annual Conflict of Interest Disclosure for Board Members & Staff
After reading the above Conflict of Interest Policy, please complete the following questions. If you have any questions or concerns, you can reach out to Donate Life Northwest's Executive Director or Operations Director (lewissa@ohsu.edu)