GIRLS GIVING GRANTS (g3)
CONFLICT OF INTEREST POLICY AND AGREEMENT
1. Purpose
The purpose of this Conflict of Interest Policy is to assist the Co-Chair(s) of Girls Giving Grants (g3), the Advisors and Members of Girls Giving Grants (collectively, “Members”) in identifying and avoiding situations that present potential conflicts of interest. Girls Giving Grants is committed to avoiding potential conflicts of interest in order (1) to protect the integrity of Girls Giving Grants’ decision-making process, (2) to ensure that our Grant Applicants and the nonprofit community as a whole, have confidence in our integrity, and (3) to protect the integrity and reputations of all Members of Girls Giving Grants. This Conflict of Interest policy also provides Girls Giving Grants with a procedure that permits a Grant Applicant to be considered for Girls Giving Grants’ grant award even though one or more Members may have a conflict of interest with respect to the Grant Applicant.
2. Standard of Behavior
A Member of Girls Giving Grants may not use her position with Girls Giving Grants to achieve a personal benefit for herself, whether financial or non-financial, directly or indirectly. Girls Giving Grants’ Members must scrupulously avoid conflicts of interest between the interests of Girls Giving Grants and personal, scholastic, extra-curricular, professional and business interests. This includes avoiding potential and actual conflicts of interest, as well as taking affirmative action to avoid perceptions of conflicts of interest. This policy is intended to supplement but not replace any applicable laws governing conflicts of interest in nonprofit and charitable organizations.
3. Conflict of Interest Defined
A conflict of interest may arise if a Member has a personal, organizational or professional interest that is in conflict with the best interest of Girls Giving Grants. A Member is usually considered to have a conflict of interest if she or a Family Member:
a. Has a substantial financial interest in any Grant Applicant or in any organization having a substantial financial interest in any Grant Applicant. A “substantial financial interest” in an entity is a financial interest of any kind, which, in view of all the circumstances, is substantial enough that it would, or reasonably could, affect the judgment of the Member or her Family Member.
b. Holds a position (whether paid or unpaid) as a trustee, director, general manager, Board Member, partner, principal officer, representative, consultant or employee of any Grant Applicant.
c. Holds a position (whether paid or unpaid) as a trustee, director, general manager, Board Member, partner, principal officer, representative, consultant or employee of any organization that performs functions similar to Girls Giving Grants.
d. Uses “inside information” for personal benefit, benefit to any Grant Applicant, or to the detriment of Girls Giving Grants. “Inside information” is information that has not been made public and was obtained through the Member’s work or position with Girls Giving Grants.
e. Uses her position with Girls Giving Grants for a personal, professional or organizational benefit that is in conflict with the best interest of Girls Giving Grants.
f. Accepts gifts, entertainment or other favors from any Grant Applicant or potential Grant Applicant or from any charitable organization operating in Travis, Williamson, Bastrop or Hays counties, Texas, under circumstances where it might be inferred that such action was intended to influence or possibly would influence the Member in the performance of her duties on behalf of Girls Giving Grants.
g. Has or promotes an interest which results in, or may be reasonably perceived to result in, an interference with the objectivity with which the Member is expected to exercise her duties on behalf of Girls Giving Grants.
4. Definitions
a. “Co-Chair(s) of Girls Giving Grants” is any Member of the Board of Directors of Impact Austin that serves as the managing liaison between Girls Giving Grants and Impact Austin.
b. “Member” is any Member of Girls Giving Grants.
c. “Advisor” is any individual selected by the Board of Directors of Impact Austin or the Co-Chair(s) of Girls Giving Grants to advise Girls Giving Grants youth members.
d. “Family Member” is a parent, step-parent, brother, step-brother, sister, step-sister, spouse of a brother or sister, or in-law, grandparent, step-grandparent, of a Member.
e. “Grant Applicant” is a person or organization that has received, is receiving or is seeking to receive a grant or other financial commitments from Girls Giving Grants.
5. Duty to Disclose
a. Prior to attending the Application Review Committee (“ARC”) meeting, each Member is required to review a copy of this Conflicts of Interest Policy and to acknowledge in writing that she has done so by signing below.
b. Prior to attending the ARC meeting, each Member is also required to complete a Conflict of Interest Disclosure Form (attached) identifying any relationships, positions or circumstances that the Member believes could contribute to a conflict of interest arising, including but not limited to any affiliation with any Grant Applicant. Such Conflict of Interest Disclosure Form shall be updated annually.
c. Any information disclosed on the Member’s Conflict of Interest Disclosure Form shall be treated as confidential and shall generally be made available only to Co-Chair of Girls Giving Grants, Advisors and ARC Chairs, except to the extent additional disclosure is necessary in connection with the implementation of this policy.
d. The Members shall review this policy annually. Any changes to the policy shall be communicated immediately to all Members of Girls Giving Grants.
6. Procedures Where a Conflict of Interest is Present
A Grant Applicant may still be considered for Girls Giving Grants’ grant notwithstanding the existence of a conflict of interest, provided that the following procedures are strictly adhered to:
a. Prior to any action by the ARC, a Member who has a conflict of interest and who is in attendance at the meeting shall disclose all facts material to the conflict of interest. Such disclosure shall be reflected in the minutes of the meeting.
b. A Member who does not plan to attend a meeting at which she has reason to believe that the ARC will act on a matter in which the person has a conflict of interest shall disclose to the Advisor of the meeting all facts material to the conflict of interest. The Advisor shall report the disclosure at the meeting and the disclosure shall be reflected in the minutes of the meeting. If the Member having the conflict of interest is the Advisor, then the required disclosure shall be made to, and the required report be made by, the secretary.
c. A Member who has a conflict of interest shall not participate in the discussion of the matter except to disclose material facts and to respond to questions. Such person shall not attempt to exert her personal influence with respect to the matter, either at or outside the meeting.
d. If it is not entirely clear whether or not a conflict of interest exists, then the Member with the potential conflict shall disclose the circumstances to the Advisor of the meeting, who shall upon discussion with the Co-Chair(s) of Girls Giving Grants, determine whether there exists a conflict of interest that is subject to this policy.
7. Violation of this Policy
a. If any Member of Girls Giving Grants has reasonable cause to believe that a Member has failed to disclose an actual or possible conflict of interest, she shall immediately inform any Advisor and the Co-Chair(s) of Girls Giving Grants of the basis for such belief. The Member with the possible conflict should then be afforded an opportunity to explain the alleged failure to disclose.
b. If, after hearing the explanation provided by the Member who allegedly violated this policy, and making such further investigation as may be warranted in the circumstances, the Advisors and the Co-Chair(s) of Girls Giving Grants determines that the Member has, in fact, failed to disclose an actual or possible conflict of interest, it shall consider appropriate disciplinary and corrective action, including those listed in section 7c, below.
c. The violation of this Conflict of Interest Policy is a serious matter and may constitute cause for removal of the Member from the ARC for which she serves. It may also warrant dismissing the Grant Applicant involved from consideration for Girls Giving Grants’ grant award.
8. Confidentiality
Each Member shall exercise care not to disclose confidential information (a) acquired in connection with such status, or (b) the disclosure of which might be adverse to the interests of Girls Giving Grants. Furthermore, no Member shall disclose or use information relating to the business of Girls Giving Grants for the personal profit or advantage of any Member, any Family Member, or any Grant Applicant.
We have reviewed and discussed this Policy and we understand that this policy is meant to supplement good judgment, and will respect its spirit as well as its wording.