Conflict of Interest Policy
Conflict of Interest Policy
Ventura County Library Foundation
Adopted December 1, 2016
Purpose of the Statement of Policy
The Foundation is committed to integrity and fairness in the conduct of all of its activities. Inevitably, the interest of directors and employees will involve them in organization , causes and , other endeavors that intersect with the affairs of the Foundation. It would disadvantage the Foundation to deprive it of the involvement of interested colleagues, but their participation in Foundation decision making cannot impair the fairness and integrity of Foundation processes
This statement of principle is intended to further the work of the Foundation by facilitating the substantive contributions of its Directors and employees through providing for disclosure of other interests and by requiring abstention from decision-making actions that affect non-foundation affiliations of interests. In addition, the foundation would suffer if there were any appearance of bias or self-interest in its activities. These principles are intended to preclude any such appearance.
This statement is not a codification of rules of conduct; rather it is an expression of intention and purpose which should be interpreted and applied
to achieve its stated objective. Individuals worthy of affiliation with the Foundation will govern themselves by that spirit.
Disclosure. Directors and employees of the Foundation are committed to communicating fully with the Foundation regarding any relationship or commitment that could affect the impartial fulfillment of their role in the affairs of the foundation. This policy refers to such a relationship or commitment as affiliation. Affiliation may be defined as the close involvement with a vendor, service provided or grantee on the part of (a) a director of the Foundation, (b) a staff member of the foundation or (c) the spouse or equivalent, parents or children of a director or staff member. Affiliation includes, but is not limited to, serving as a board member, employee or consultant to a current or potential grantee, service provider or vendor, or doing business with the grantee, service provider or vendor. Antecedent affiliation and indirect association as warrant disclosure. In principle, extra-Foundation affiliations or interests should be disclosed to other participants in the Foundation’s decision-making process whenever there is any doubt about whether disclosure is required. Disclosures ordinarily should be made to the president by members of the staff and to the chair of the board by other members of the board of directors. Formal notation of disclosures should be part of the process
Abstention from Foundation Decision-making. In all situation in which disclosure of affecting relationships should be made, the foundation-affiliated individual should abstain from decision-taking actions, and that abstention should be formally noted in the foundation’s minutes. With disclosure to other participants, the work of the Foundation is furthered by the willingness of its Directors and employees, however interested, to share information bearing upon the matter under consideration. Such participation is encouraged.
No Return Benefit. In considering any decision regarding an organization or person with which a Foundation employee or direct is affiliated, the Foundation shall avoid any transaction that results in any direct or indirect economic benefit to the affiliated person or that would constitute self-dealing under Internal Revenue Code Section 4941. Incidental and tenuous benefits to affiliated persons, such as name recognition or public acknowledgment are permitted.
Avoid the Appearance of Conflict While the substance of integrity is the essence of the Foundation’s approach to this matter. Avoiding the appearance of conflict is an important collateral objective. To that end, the Foundation will not customarily make grants to or contract with, organization that employ affiliated persons, The chair, with the concurrence of the Treasurer may approve exceptions to this policy when the work of the foundation will be furthered thereby or where the grant or contract will not affect the job or compensation of the affiliated person in question.
No significant personal benefit of any nature may be derived by any affiliated person from any such organization.