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The Irs recently released a new Form 990, which
now includes the question. “Do you have a conflict
of interest policy?” Since the nonprofit must check “yes” or “no,” does
this create a de facto need for such a policy? Probably
so, unless you're comfortable with checking “no” on
a public document.
What should go in a conflict of interest policy?
According to Greater Boston's Community Foundation,
it should have three essential elements
- Full disclosure . Board members and staff
members in decision-making roles should make known
their connections with groups doing business with
the organization. This information should be provided
annually.
- Board member abstention from discussion and
voting. Board members who have an actual
or potential conflict of interest should not
participate in discussions or vote on matters
affecting transactions between the organization
and the other group.
- Staff member abstention from decision-making. Staff
members who have an actual or potential conflict
should not be substantively involved in decision-making
such transactions.
For additional help with conflict of interest policy,
visit the IRS website to obtain the instructions
for completing Form 1023 (The Application for Exemption
under Section 501 (c) (3)).
A suggested conflict of interest policy starts on
page 25 of the downloadable document. |
