Conflict of interest form free download






















It can also become the basis of important policy decisions and help set conflict of interest standards. This sample conflict of interest form is designed for you to download it, make it your own by adding your brand language, adjusting the phrasing of the questions and then distribute to your board of directors and employees either electronically as a PDF or via hardcopy using the print option.

While the industry is moving toward a more automated and technologically aided approach to COI, this form can help ease the transition from a solely paper-based program into a more digital program with a stronger audit trail. Think your compliance program may require a more comprehensive disclosures solution?

Download our COI software brochure below. Do you need a comprehensive disclosures solution that covers conflicts of interest, gifts, travel, and entertainment, outside employment, and more? Check out our Disclosures solution.

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Interested Parties are also required to complete an annual disclosure form to describe any ongoing interest that may create a conflict. After the Board receives any potential conflict or conflict disclosure from an Interested Party, the Board may request follow-up discussions or additional information. At this point, the Board will decide whether an actual conflict exists and whether it involves financial interest, material competition, self-dealing, or any other type of conflict.

The Interested Party shall be screened from any discussions or voting regarding the conflict. The Board may fully determine the issue on a vote or may refer it to a specialized committee for additional investigation.

Evaluation of conflicts is made on a case-by-case basis. Factors for consideration. The Board may consider any factor it wishes in determining whether a conflict exists.

Some of the factors for consideration may include:. Determination of self-dealing. If the Board or committee determines that an actual conflict exists, the Board or committee must also determine whether a self-dealing transaction is at issue.

If so, the entirety of the Board must vote on whether to approve the transaction, and the transaction must be approved by a greater vote than other Board actions. In other words, if the Board generally approves actions via a simple majority, a greater vote than this is needed to approve a self-dealing transaction. Approval of compensation for a director acting as director or officer shall not be considered a self-dealing transaction.

Determination of transactional conflict. If the Board or committee determines that an actual conflict exists involving a financial transaction or arrangement, but it is not self-dealing, the Board will consider alternative scenarios that would not present a conflict.

If the Board determines an appropriate alternative exists, the Board shall pursue that avenue. If an appropriate alternative does not exist, the Board shall determine whether the original proposed course of action is in the Organization's best interest and take a vote on such issue, in which a majority is required.

Determination of other conflict. In any other scenario in which the Board or committee determines a conflict exists, the Board or committee shall recommend a reasonable and appropriate course of action to protect the Organization.

The governing body shall discuss the issue and determine how best to proceed forward. If an Interested Party fails to disclose any potential or actual conflict, the Board shall first request an explanation from the Interested Party.

The Board may then determine appropriate action, including disciplinary action if required. The Board or relevant committee shall retain all records of discussions and votes regarding any presented conflict or potential conflict.

The records must specifically include:. How the conflict was brought to the attention of the Board whether disclosed or found out ;. The nature of the possible conflict, including financial interest involved;. The Board or committee's actions regarding fact-finding and investigation on the conflict or potential conflict;. No Board member who is compensated for their services towards the Organization may vote on their own compensation. All individuals required to abide by this Policy must sign a statement each year attesting that they have received a copy of the Policy, they read and understand the Policy, they agree to comply with the Policy, and they understand the Organization's maintenance of its charitable activities and federal tax exemption depends on its undertaking primarily of activities that support its charitable purpose.

Any individual that believes they have ongoing relationships or interests that may present a conflict must also make an annual disclosure, as described above, and is responsible for updating such disclosure upon the occurrence of any material change. The Organization will periodically review certain subjects to maintain alignment with its charitable purposes.



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