Conflict of Interest Policy and Acknowledgement and Disclosure Form

Instructions: Please read the policy below and complete and submit the acknowledgement and disclosure form at the bottom of the page.  

Conflict of Interest Policy

Anyone making decisions on behalf of Street Law, Inc. should always act based on the best interests of the organization, and no individual associated with Street Law, Inc. should use their position for personal benefit, for the benefit of friends or relatives, or to further any outside interests or personal agenda. This standard applies to all transactions and decisions, whether or not covered by the detailed policies and procedures below.

This policy applies to any person who is a director, officer, member of a committee, or staff member of Street Law, Inc. (an “interested person”).

Definition

A potential conflict of interest exists whenever the professional or financial interest of an interested person is opposed to that of the organization, or when such an interest or any conflicting fiduciary duty might influence the interested person’s actions and judgment on behalf of Street Law, Inc. A potential conflict also exists when there is an appearance that an interested person’s actions may be influenced by a competing interest or duty.

A conflict of interest exists whenever an interested person’s competing interest or fiduciary duty is substantial enough that the interested person cannot be expected to exercise independent judgment and take action in the best interest of Street Law, Inc.

Conflicts of interest most frequently arise in (but are in no way limited to) the following contexts:

• Decisions about an interested person’s compensation (as a contractor or employee); 
• Decisions about transactions with entities in which an interested person holds an ownership interest;
• Decisions about transactions with an entity by which an interested person is employed;
• Acceptance of gifts or any other item of value from any person or entity who may be seeking special treatment; and
• Use of Street Law’s equipment, materials, or property for personal or third-party gain.

Conflicts (or the appearance of conflicts) may also arise when Street Law, Inc. is contemplating a transaction with a close relative or domestic partner of an interested person, or any entity in which such a related person has an ownership interest or which employs such a person.

Conflicts of interest should not be considered to arise when the potential benefit to the interested person is tenuous or remote, such as an interested person with investments in a mutual fund that holds a small amount of stock in a particular company. The fact that an interested person is also a director, officer, member, or volunteer for a nonprofit organization that obtains or seeks funds from institutions or individuals from which Street Law, Inc. also obtains or seeks funds will not by itself be deemed to be a conflict of interest.

Procedure: Board of Directors

Whenever a director, officer, or committee member becomes aware of a potential conflict of interest, whether financial or otherwise, they shall make the situation known to the board or committee chair (as the case might be) and provide all facts material to understanding the nature and scope of the conflict, including whether the interested person believes their ability to make an independent decision based solely on the best interest of Street Law, Inc. has been compromised. If the interested person involved does not make this disclosure, another director or committee member with knowledge of the potential conflict should draw it to the body’s attention.

The interested person with the potential conflict must retire from the meeting and not participate in the final discussion and voting on the existence of the conflict. If a conflict is found to exist, the interested person may be invited to provide any relevant information that could be of use to the board in making its decision, but shall again retire and not participate in the final discussion and voting regarding the transaction.

The board or committee’s decision shall be based on consideration of whether the transaction

• Is in the organization’s best interest and for its own benefit
• Is fair and reasonable to the organization
• Is the most advantageous transaction or arrangement the organization can obtain with reasonable efforts under the circumstances.

Procedure: Staff

Whenever a staff member becomes aware of a potential conflict of interest in an area where they exercise any discretion in carrying out their duties for Street Law, Inc., the employee shall promptly disclose the potential conflict to an immediate supervisor, who will in turn inform their senior management team (SMT) liaison. If the CEO has a potential conflict, they must disclose it to the board chair. The SMT liaison, or the board chair in the case of the CEO, will determine whether there is a conflict that requires recusal of the interested person. When a conflict is found to exist, the interested person shall provide the SMT liaison or board chair with all information they have that is relevant to any decision to be made in which they have an interest, and the final decision shall be made by the SMT liaison or board chair.  

Annual Distribution Acknowledgement and Disclosure Form

This conflict of interest policy shall be distributed annually to all directors, officers, members of board committees, and staff. All covered individuals shall sign an annual acknowledgement that they have received a copy of this policy, understand it, and agree to abide by its terms.

Additionally, the annual acknowledgement form provides an opportunity for Directors to disclose all paid or unpaid positions or relationships that may present a conflict of interest. Street Law requests that all Directors provide a supplemental disclosure if a new relationship arises during the year that may be a conflict of interest. These annual acknowledgement forms, as well as any supplemental disclosures, will be reviewed by the senior management team, which will take necessary steps should there be a need.

I have read the Conflict of Interest Policy of Street Law (above).

To the best of my knowledge and belief, neither I nor any person or organization with whom I have a personal or business relationship is engaged in any transaction or activity that may represent a conflict with my obligations to Street Law.

To the best of my knowledge and belief, neither I nor any person or organization with whom I have a personal or business relationship intends to engage in any transaction, to acquire any interest in any organization or entity, or to receive any substantial gift or favor that may represent a conflict with my obligations to Street Law.

To the best of my knowledge and belief, I do not expect to receive compensation from Street Law, or to receive in excess of $10,000 annually from Street Law for services I provide to Street Law as an independent contractor, other than reimbursement of reasonable expenses.

To the best of my knowledge and belief, no member of my family expects to receive any compensation or material financial benefit from Street Law.

To the best of my knowledge and belief, I have no family relationship or business relationship with any current member of the Board of Directors, any officer, or any key employee of Street Law, other than in the ordinary course of business.

I am not a Government Official, nor is an immediate family member of mine a Government Official, according to the following definitions: 

• An elected or appointed officials, employees, or representatives of a non-U.S. government (which includes the executive, legislative, administrative, military, or judicial branches of a government; a political party; or a government-owned, government controlled, or government-funded corporation, institution or charity) at any level.
• An elected U.S. Public Officials including but not limited to U.S. Representatives and U.S. Senators, Governors, State Senators and Representatives, City Council Representatives, any other elected officials at the state and local levels, and members of any elected officials’ staff; and all political appointees, including any individual appointed by an executive official at the federal, state or local level (e.g., President, Governor, etc.) and members of their staff.

For Directors, please list in the form below all paid or unpaid positions or relationships with nonprofit or for-profit third-party organizations that compete with Street Law, or take public positions contrary to those of Street Law, or any relationship that may compromise your ability to provide unbiased and undivided loyalty to Street Law. 

Any exception to the statements made herein is disclosed in full below.