1. Policy Statement
Family Promise of Puget Sound (FPOPS) is committed to upholding the highest standards of integrity, transparency, and accountability in all its operations. As a non-profit organization, we must ensure that all decisions and transactions are made in the best interest of our mission and the families we serve, free from any personal financial gain or undue influence. This policy establishes guidelines to identify, disclose, and resolve actual, potential, or perceived conflicts of interest involving individuals affiliated with FPOPS.
2. Purpose
The purpose of this policy is to:
* Protect FPOPS’s Tax-Exempt Status: Safeguard the organization’s 501(c)(3) tax-exempt status by preventing “private benefit” or “excess benefit transactions” that could jeopardize our charitable mission.
* Ensure Best Interests: Ensure that all transactions, decisions, and arrangements are conducted solely in the best interest of Family Promise of Puget Sound.
* Promote Transparency: Foster an environment of openness and trust by clearly outlining expectations for disclosure.
* Maintain Public Trust: Preserve the public’s confidence in FPOPS’s integrity and stewardship of resources.
3. Scope
This policy applies to all individuals who have the ability to influence the decisions or financial dealings of Family Promise of Puget Sound. This includes, but is not limited to:
* All Members of the Board of Directors
* All Paid and Unpaid Employees (including full-time, part-time, temporary staff, and the CEO)
* All Volunteers who hold positions of significant responsibility, influence, or decision-making authority within FPOPS (e.g., committee chairs, individuals involved in procurement, fundraising, or significant program decisions).
4. Definitions
* Interested Person: Any Board member, employee, or volunteer (as defined in the Scope) who has a Financial Interest in any transaction, arrangement, or decision being considered by Family Promise of Puget Sound.
* Financial Interest: An individual has a financial interest if they, directly or indirectly, through business, investment, or family:
* Have an ownership or investment interest in any entity with which FPOPS has a transaction or arrangement.
* Have a compensation arrangement with any entity or individual with which FPOPS has a transaction or arrangement.
* Are currently negotiating or have an arrangement concerning prospective employment or compensation.
* A financial interest is not necessarily a conflict of interest. It becomes a conflict of interest when the Board, a relevant committee, or FPOPS leadership determines that the financial interest could potentially influence the person’s judgment in matters involving FPOPS.
* Conflict of Interest: A situation in which an individual’s personal interests (which may include financial, business, or family interests) could potentially or actually influence their judgment or actions in the performance of their duties for Family Promise of Puget Sound.
5. Duty to Disclose
Any Interested Person who has an actual or possible conflict of interest, or who believes a conflict may arise, must:
* Promptly Disclose: Immediately disclose the existence and nature of the financial interest or potential conflict to the Board of Directors, the CEO, their direct supervisor, or the designated committee (e.g., Executive Committee).
* Provide All Material Facts: Provide all material facts concerning the financial interest or relationship to the Board, CEO, supervisor, or committee. This disclosure should be made as soon as the potential conflict is identified or becomes apparent.
6. Procedures for Determining and Addressing Conflicts
Once a disclosure is made, the following procedures will be followed to determine if a conflict exists and how to address it:
1. Recusal from Discussion: The Interested Person shall recuse themselves from the discussion and absent themselves from the meeting during the deliberation and vote on the transaction or arrangement involving the potential conflict.
2. Disclosure to Others: The disclosure of the financial interest or potential conflict will be made known to all other Board members, committee members, or relevant decision-makers present.
3. Determination of Conflict: The remaining members of the Board or relevant committee, who do not have a financial interest in the matter, shall decide by a majority vote whether a conflict of interest exists.
4. Addressing the Conflict:
* If a conflict is determined to exist, the Board or committee shall consider alternative transactions or arrangements that would not give rise to a conflict.
* If no alternative is reasonably available, the Board or committee may approve the transaction or arrangement only if it is determined to be in the best interest of FPOPS and is fair and reasonable to the organization.
* The Interested Person may be asked to provide information or answer questions but must not attempt to influence the deliberation or voting.
7. Compensation
No Interested Person who receives compensation (direct or indirect) from Family Promise of Puget Sound for services rendered shall vote on matters pertaining to their own compensation. This does not preclude them from providing information relevant to their compensation.
8. Annual Statements
All individuals covered by this policy (Board members, employees, and relevant volunteers) are required to sign an annual statement affirming that they:
* Have received, read, and understand this Conflict of Interest Policy.
* Agree to comply with the terms of this policy.
* Have disclosed any known conflicts of interest or potential conflicts.
9. Periodic Reviews
Family Promise of Puget Sound will conduct periodic reviews, at least once every three years, to ensure that:
* The organization operates in a manner consistent with its charitable purposes.
* It does not engage in activities that could jeopardize its tax-exempt status.
* The terms of this policy are being followed effectively.
10. Violations
Failure to disclose an actual or potential conflict of interest, or to comply with the procedures outlined in this policy, will be taken seriously. Consequences for non-compliance may include:
* Disciplinary Action: For employees and volunteers, this may lead to disciplinary action, up to and including termination of employment or volunteer service.
* Board Action: For Board members, this may lead to disciplinary action, including removal from the Board.
* Legal and Financial Consequences: Violations may also lead to legal and financial repercussions for the individual and/or Family Promise of Puget Sound, including loss of funding, fines, or other penalties from regulatory bodies. Individuals are expected to cooperate fully with any investigation or disciplinary action related to alleged violations.
11. Records
Records of all disclosures, discussions, and votes related to actual or potential conflicts of interest will be maintained in the official records of Family Promise of Puget Sound. These records will document the nature of the conflict, the names of the persons involved, the steps taken to address the conflict, and the outcome.
12. Policy Review and Revision
This policy will be reviewed periodically, at least annually, by the Board of Directors, or more frequently as needed, to ensure its continued effectiveness, relevance, and alignment with best practices and legal requirements. Any revisions will be communicated to all relevant personnel and stakeholders.