Conflicts of Interest Policy

Washington County Community Foundation Policy on Conflicts of Interest

Trustees: Conflicts of Interest

The Bylaws of the Washington County Community Foundation, Inc. maintain that no member of the Board of Trustees, or any of its committees, shall act upon or decide any matter with respect to which he or she has a conflict of interest. A conflict of interest exists with respect to a given matter if a member of the Board of Trustees, or a member of any committee of the Board, has a financial or fiduciary interest in another organization, business or individual that would be affected by any action of the Board, committee or staff person. A member of the Board of Trustees or any of its committees shall be construed to have a financial interest in an organization, business or individual from which he or she derives an income, and to have a fiduciary interest in an organization, business or individual for which he or she performs in the capacity of a Trustee or Director. Trustees and committee members are required to annually disclose any conflicts of interest or potential conflicts of interest they may have using this form. The President & CEO shall be responsible for securing completed forms and shall advise the Chairman and Secretary in advance of any person who has or may have a conflict on any action item to be considered by the Board, based on information previously submitted on this form. In addition, a member of the Board of Trustees or any of its committees who believes that he or she has a conflict of interest with respect to any matter shall announce to the body the existence of the conflict of interest prior to the beginning of any discussion on the matter and shall abstain from such discussion in voting on the matter, in accordance with the Bylaws, regardless of whether or not the conflict of interest was previously listed on this form and submitted to the President & CEO. All other provisions of the Bylaws with respect to conflicts of interest and resolution of the same shall be followed. Minutes of any action taken by the Board shall reflect any and all persons who have a conflict.

Employees: Conflicts of Interest With Respect to Specific Matters

The Bylaws of the Washington County Community Foundation, Inc., and the Employee Conflicts of Interest Policy prohibit an employee from acting upon or deciding any matter with respect to which he or she has a conflict of interest.

A conflict of interest exists with respect to a given matter if an employee has a financial or fiduciary interest in another organization, business or individual that would be affected by the action of the Foundation, including an action taken by any person, committee or other entity on the Foundation's behalf.

A conflict of interest also exists with respect to a given matter, if the Foundation would be affected by the action taken by another organization, business or individual in which an employee has a financial or fiduciary interest, including an action taken by any person, committee or entity on behalf of that organization, business or individual.

An employee shall be construed to have a financial interest in an organization, business or individual from which he or she derives an income, and to have a fiduciary interest in an organization, business or individual for which he or she performs in the capacity of a trustee or director.

Any employee who believes that he or she may have a conflict of interest with respect to a given matter must submit the required form to the President & CEO prior to having any involvement with the matter, whether on behalf of the Foundation or on behalf of any other organization, business or individual in which the employee has a financial or fiduciary interest.

Employees: Conflicts of Interest Annual Disclosure

The Bylaws of the Washington County Community Foundation, Inc., and the Employee Conflicts of Interest Policy prohibit an employee from acting upon or deciding any matter with respect to which he or she has a conflict of interest.

A conflict of interest exists with respect to a given matter if an employee has a financial or fiduciary interest in another organization, business or individual that would be affected by the action of the Foundation, including an action taken by any person, committee or other entity on the Foundation's behalf.

A conflict of interest also exists with respect to a given matter, if the Foundation would be affected by the action taken by another organization, business or individual in which an employee has a financial or fiduciary interest, including an action taken by any person, committee or entity on behalf of that organization, business or individual.

An employee shall be construed to have a financial interest in an organization, business or individual from which he or she derives an income, and to have a fiduciary interest in an organization, business or individual for which he or she performs in the capacity of a trustee or director.

Employees are required to annually disclose, using the required form, any financial or fiduciary interests that they have in another organization, business or individual, which may potentially create a conflict of interest with respect to matters that may at any time potentially come before the Foundation Board of Trustees or before the organization, business or individual in which the employee has a financial or fiduciary interest.

Employees: Conflicts of Interest Per Se

In accordance with the Employee Conflicts of Interest Policy, Employees are prohibited from, at any time during the course of their employment with the Foundation, being employed by or serving on the Board of an outside entity that competes, through its regularly conducted business and/or purpose for existence, with the Foundation. Such employment or service shall be deemed to be a "per se" conflict of interest. If an employee thinks that he or she may have such a "per se" conflict of interest, he or she must disclose the same immediately on the required form as soon as he or she becomes aware of even the potential per se conflict of interest, and must submit the same to the President & CEO.

Date of Adoption: November 27, 2017