Conflict of Interest Policy

Conflict of Interest Policy #

Source: OASIS Open Conflict of Interest Policy. Approved and effective March 3, 2011.

Purpose #

This policy protects OASIS’s interests when the organization considers actions that might personally benefit an officer, director, or staff member with delegated authority, or that could constitute excess benefit transactions. It supplements applicable state and federal law and applies to all Board members, corporate officers, and anyone acting under delegated authority.

As a 501(c)(6) membership organization, OASIS is obligated to ensure its decisions are made in the organization’s interest and are free from — and visibly free from — personal or financial conflicts. OASIS holds itself to a standard of being above reproach in its use of organizational resources.

What Is a Financial Interest #

A person has a financial interest if they have — directly or indirectly, through business, employment, investment, or family — any of the following in connection with a transaction or matter before the Board:

  • An ownership or investment interest in any entity with which OASIS has, or is considering, a transaction
  • A compensation arrangement with OASIS or with any entity OASIS transacts with
  • A potential ownership, investment interest, or compensation arrangement with any entity OASIS is considering engaging

A financial interest does not automatically constitute a conflict of interest — that determination is made by the Board after disclosure.

Disclosure Obligations #

Board members and corporate officers must disclose any financial interest and all material facts regarding actual or possible conflicts whenever the Board is considering a proposed transaction, arrangement, or appeal. Disclosure should be made as soon as the potential conflict is identified, not after a decision has been reached.

Procedure When a Conflict Is Identified #

  1. The interested person may provide information and answer questions about the transaction
  2. The interested person leaves the room while the Board discusses whether a conflict exists
  3. If the Board determines a conflict exists, the interested person may present their position on the merits but must leave during deliberation and voting
  4. Disinterested Board members determine whether the arrangement serves OASIS’s best interests and is fair and reasonable
  5. The interested person does not vote on the matter

Staff with Delegated Authority #

These procedures apply not only to Board members and officers but to all staff acting under delegated authority. If you become aware of a potential conflict between your personal interests and your responsibilities to OASIS, disclose it to the (Interim) ED or a Staffing Committee member immediately. When in doubt, disclose — the cost of disclosure is low; the cost of undisclosed conflicts is not.

Violations #

Failure to disclose a known conflict is itself a violation of this policy. The Board investigates alleged failures to disclose, affords the person an opportunity to explain, and takes appropriate disciplinary action where a violation is confirmed.

Annual Statements #

Each Board member and corporate officer signs an annual statement affirming they have received, read, and understood this policy and acknowledge OASIS’s tax-exempt status requires primarily exempt-purpose activities.

Record-Keeping #

Board minutes must document: the names of persons with financial interests, the nature of those interests, actions taken to determine whether conflicts existed, the Board’s determination, alternatives discussed, and individual vote records.