Purpose
The purpose of this policy is to protect the interests of [organization name] by: (a) preventing the personal interest of the Board, Employees, and Independent Contractors from interfering with their duties to the organization and (b) avoiding any unethical financial, professional, or political gain on the part of such individuals. The intent of this policy is to supplement, not replace, any applicable federal, state, or local laws regarding conflicts of interest.
Persons Concerned
This statement applies to Board Members, Officers, and all Employees who can influence the governance and actions of cer Financial. This includes anyone who makes financial decisions, might be referred to as “management personnel,” or have proprietary information regarding cer Financial.
Procedures
1. Duty to Disclose
Each Member, Director, Officer, Employee, and any other Interested Person is under an obligation to disclose the existence or potential existence of a Conflict of Interest as it arises.
2. Investigating Conflicts
When a potential Conflict of Interest is disclosed, the Governing Board will then provide the individual with an opportunity to disclose all material facts. The Board will collect all pertinent information and question the involved parties. If it turns out that a conflict does not exist, the inquiry will be documented but no further action will be taken.
3. Addressing a Conflict of Interest
If the Board determines that a conflict of interest exists, they will take the appropriate actions to address the conflict. This may include (but not be limited to): (a) prohibiting any Interested Parties from voting on any matter related to said Conflict of Interest or (b) terminating employment with cer Financial.
Affected parties both within and outside of cer Financial, including shareholders, directors, employees, and independent contractors, will be notified. If the Conflict of Interest in question involves a member of the Board, that individual will be excused from deliberations.
4. Disciplinary Action
All conflicts of interest will be reviewed on a case-by-case basis. The board has full discretion to deem what disciplinary action is appropriate and necessary for disclosed conflicts of interest.
If the governing officers reasonably believe a member or staff member failed to disclose an existing or possible Conflict of Interest, it shall inform the individual of the rationale for such belief and grant the individual an opportunity to explain the alleged failure to disclose the Conflict of Interest.
After hearing the individual’s response and investigating further as warranted by the circumstances, the governing officers may take appropriate disciplinary action, including removal from the position at the organization.
5. Notice of Annual Statements
Every Member, Director, Officer, Employee, and any other Interested Person must sign a Conflict of Interest Disclosure Statement upon said individual’s term of office, employment, or other relationship with [organization name] and must do so annually. Failure to sign does not nullify the policy.
Acknowledgment
By signing, the individual named below understands what constitutes a Conflict of Interest and understands the procedure for addressing them with cer Financial, including their duty to disclose any known or potential conflicts of interest.
The signee agrees to abide by the procedures set forth by this policy for the duration of their relationship with cer Financial.
Signed by
cer Financial – Managing Director