policies Changeset - 1ca3ced3fd87 · Conservancy Kallithea

file renamed from Conflicts/conflict-of-interest-policy.tex to Conflicts/conflict-of-interest-policy.txt

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Software Freedom Conservancy Conflict of Interest Policy

========================================================

:Date:      1 March 2012

\title{Software Freedom Conservancy Conflict of Interest Policy}

== Purpose

\maketitle

The purpose of this conflict of interest policy (``Policy'')  is to protect

the Software Freedom Conservancy (``Conservancy'') and its Member Projects

when Conservancy contemplates entering into a transaction or arrangement

that might benefit the private interest of a Director, Officer or Staff

Member of Conservancy or a member of a Project Leadership Committee

(``PLC''), or might otherwise result in a possible excess benefit

transaction. This Policy is intended to supplement but not replace any

applicable state and federal laws governing conflict of interest

applicable to nonprofit and charitable organizations.

\section{Purpose}

The purpose of this conflict of interest policy (``Policy'') is

to protect the Software Freedom Conservancy (``Conservancy'') and

its Member Projects when Conservancy contemplates entering into a

transaction or arrangement that might benefit the private interest

of a Director, Officer or Staff Member of Conservancy or a member

of a Project Leadership Committee (``PLC''), or might otherwise

result in a possible excess benefit transaction. This Policy is intended

to supplement but not replace any applicable state and federal laws

governing conflict of interest applicable to nonprofit and charitable

organizations.

\section{Conservancy Directors, Officers and Staff}

== Conservancy Directors, Officers and Staff

Directors, Officers and Staff Members of Conservancy (``Conservancy

Persons'') each have a duty to protect Conservancy and its Member

Projects from violating state and federal laws - and to avoid any

appearance of impropriety. Conservancy Persons serve the public interest

and are to have a clear understanding of Conservancy's charitable

mission. All decisions made by Conservancy Persons are to be made

solely on the basis of a desire to promote the best interests of Conservancy

and the public good.

Persons'') each have a duty to protect Conservancy and its Member Projects

from violating state and federal laws - and to avoid any appearance of

impropriety. Conservancy Persons serve the public interest and are to have

a clear understanding of Conservancy's charitable mission. All decisions

made by Conservancy Persons are to be made solely on the basis of a desire

to promote the best interests of Conservancy and the public good.

\subsection{Defining a Conflict of Interest for a Conservancy Person}

=== Defining a Conflict of Interest for a Conservancy Person

...

@@ -42,17 +32,20 @@ In general, Conservancy Persons should avoid making decisions on matters

where their personal interests are at odds with the Conservancy's

interests. In particular, the following scenarios are to be identified

as conflicts of interest:

\begin{itemize}

\item A Conservancy Person (or his or her family member) is a party to a

interests. In particular, the following scenarios are to be identified as

conflicts of interest:

* A Conservancy Person (or his or her family member) is a party to a

contract, or involved in a transaction with Conservancy for goods

or services.

\item A Conservancy Person (or his or her family member) is a director,

officer, agent, partner, associate, employee, trustee, personal representative,

receiver, guardian, custodian, legal representative or in some other

way has a fiduciary duty to an entity involved in a transaction with

Conservancy.

\item A Conservancy Person (or his or her family member) is engaged in some

* A Conservancy Person (or his or her family member) is a director,

officer, agent, partner, associate, employee, trustee, personal

representative, receiver, guardian, custodian, legal representative or in

some other way has a fiduciary duty to an entity involved in a transaction

with Conservancy.

* A Conservancy Person (or his or her family member) is engaged in some

capacity or has a material financial interest in a business or enterprise

that competes with Conservancy or a Conservancy Project.

\item A Conservancy Person (or his or her family member) has a material

* A Conservancy Person (or his or her family member) has a material

financial interest in, or fiduciary duty to an entity Conservancy

...

@@ -60,3 +53,4 @@ has engaged in a free software license compliance effort, enforcement

effort, or related litigation on behalf of a Conservancy project.

\item A Conservancy Person (or his or her family member) has a material

* A Conservancy Person (or his or her family member) has a material

financial interest in or fiduciary duty to the competitor of an entity

...

@@ -65,14 +59,14 @@ enforcement effort, or related litigation on behalf of a Conservancy

project.

\end{itemize}

Conservancy acknowledges that other situations may create the appearance

of a conflict, or present a duality of interests. All such circumstances

should be disclosed to the Board, as appropriate, and the Board shall

make a decision as to what (if any) course of action Conservancy or

relevant Conservancy Persons should take so that Conservancy's best

interests are not compromised by personal interests.

should be disclosed to the Board, as appropriate, and the Board shall make

a decision as to what (if any) course of action Conservancy or relevant

Conservancy Persons should take so that Conservancy's best interests are

not compromised by personal interests.

=== General Policies for Conservancy Persons

\subsection{General Policies for Conservancy Persons}

\begin{itemize}

\item \textbf{No Personal Profit or Gain.} No Conservancy Person (or family

* *No Personal Profit or Gain.* No Conservancy Person (or family

member) shall derive any personal profit or gain, directly or indirectly,

...

@@ -81,3 +75,4 @@ or gain does not include compensation approved by the Board for paid

employees.

\item \textbf{Disclosure and Abstention when Conflicted.} Each Conservancy

* *Disclosure and Abstention when Conflicted.* Each Conservancy

Person shall disclose to Conservancy's Board any conflict of interest

...

@@ -85,11 +80,12 @@ which he or she may have in any matter pending before Conservancy

and shall refrain from participation in any decision on such matter.

\item \textbf{Conservancy Conflict Disclosure Form.} Every six months, each

* *Conservancy Conflict Disclosure Form.* Every six months, each

Conservancy Person shall complete a Conservancy Conflict Disclosure

form {[}attached as Exhibit A{]} and submit it to the Board and to

form <<Exhibit-A,attached as Exhibit A>> and submit it to the Board and to

Conservancy's General Counsel.

\end{itemize}

\subsection{Conflict Resolution Procedures for Conservancy Persons}

\begin{itemize}

\item \textbf{Disclosure of Conflict When Present.} Prior to any Board or

=== Conflict Resolution Procedures for Conservancy Persons

* *Disclosure of Conflict When Present.* Prior to any Board or

Board Committee action on a matter or transaction involving a conflict

...

@@ -102,3 +98,4 @@ the board member or by the interested person him/herself if invited

to the Board meeting as a guest for purposes of disclosure.

\item \textbf{Disclosure of Conflict When Absent. }A Conservancy Person

* *Disclosure of Conflict When Absent.* A Conservancy Person

who plans not to attend a meeting at which he or she has reason to

...

@@ -109,4 +106,5 @@ report the disclosure at the meeting and the disclosure shall be reflected

in the minutes of the meeting.

\item \textbf{Participation in Discussions and Votes Regarding Conflicted

Matter.} A conflicted Conservancy Person shall not participate in

* *Participation in Discussions and Votes Regarding Conflicted Matter.*

A conflicted Conservancy Person shall not participate in

or be permitted to hear the Board's or Board Committee's discussion

...

@@ -116,3 +114,4 @@ Conservancy Person shall not attempt to exert his or her personal

influence with respect to the matter, either at or outside the meeting.

\item \textbf{Participation in Votes Regarding Conflicted Matter.} A conflicted

* *Participation in Votes Regarding Conflicted Matter.* A conflicted

Conservancy Person may not vote on the Board action with which he

...

@@ -122,3 +121,4 @@ or her ineligibility to vote shall be reflected in the minutes of

the meeting.

\item \textbf{Conflicted Persons Cannot Establish Quorum.} A conflicted

* *Conflicted Persons Cannot Establish Quorum.* A conflicted

Conservancy Person shall not be determining the presence of a quorum

...

@@ -126,3 +126,4 @@ for purposes of a vote on the matter where he or she has a conflict

of interest.

\item \textbf{Managing an Officer's Conflict of Interest. }If a Conservancy

* *Managing an Officer's Conflict of Interest.* If a Conservancy

Person is an Officer involved in a decision, matter or transaction

...

@@ -135,3 +136,4 @@ of the conflict and the Board's subsequent actions in the minutes

of the next meeting.

\item \textbf{Managing a Staff Member's Conflict of Interest.} If a Conservancy

* *Managing a Staff Member's Conflict of Interest.* If a Conservancy

Person is a Staff Member who has been assigned duties that involve

...

@@ -143,3 +145,4 @@ and/or other actions taken by the Staff Member regarding the conflicted

matter, and file a written report acknowledging the potential conflict.

\item \textbf{Confidentiality of Conflict Disclosures.} Each Conservancy

* *Confidentiality of Conflict Disclosures.* Each Conservancy

Person shall exercise care not to disclose confidential information

...

@@ -149,3 +152,3 @@ potential conflicts, which might be adverse to Conservancy's interests.

\section{Project Leadership Committees}

== Project Leadership Committees

...

@@ -161,3 +164,3 @@ decisions about the Project.

\subsection{Defining a Conflict of Interest for a PLC Person}

=== Defining a Conflict of Interest for a PLC Person

...

@@ -167,10 +170,12 @@ at odds with his or her Project's interests. In particular, the following

scenarios are to be identified as conflicts of interest:

\begin{itemize}

\item A PLC Person (or his or her family member) is a party to a contract,

* A PLC Person (or his or her family member) is a party to a contract,

or involved in a transaction with Conservancy for goods or services

relating to his or her Project.

\item A PLC Person (or his or her family member) is an employee, owner,

* A PLC Person (or his or her family member) is an employee, owner,

or otherwise has a financial interest in an entity involved in a transaction

with Conservancy relating to his or her Project.

\item A PLC Person (or his or her family member) is a director, officer,

* A PLC Person (or his or her family member) is a director, officer,

agent, partner, associate, trustee, receiver, guardian, personal representative,

...

@@ -179,6 +184,8 @@ to an entity involved in a transaction with Conservancy relating to

his or her Project.

\item A PLC Person (or his or her family member) is engaged in some capacity

* A PLC Person (or his or her family member) is engaged in some capacity

or has a material financial interest in a business or enterprise that

competes with his or her Project.

\item A PLC Person (or his or her family member) is the owner of copyrights

* A PLC Person (or his or her family member) is the owner of copyrights

that are the subject of a Conservancy-led compliance effort, enforcement

...

@@ -187,3 +194,3 @@ has a material financial interest in or fiduciary duty to an entity

adverse to this effort.

\end{itemize}

Conservancy further notes that a scenario may arise where a PLC Person

...

@@ -206,8 +213,10 @@ interests.

\subsection{General Policies for PLC Persons}

\begin{itemize}

\item \textbf{No Compensation for PLC Persons.} No PLC Person shall receive

=== General Policies for PLC Persons

* *No Compensation for PLC Persons.* No PLC Person shall receive

any salary or other substantial benefit from Conservancy as compensation

for his or her duties as a PLC Person.

\item \textbf{Disclosure and Abstention when Conflicted.} Each PLC Person

* *Disclosure and Abstention when Conflicted.* Each PLC Person

shall disclose to his or her PLC and to Conservancy's Executive Director

...

@@ -216,5 +225,6 @@ before the PLC and shall refrain from participation in any decision

on such matter.

\item \textbf{Multiple Employees from the same Employer on a PLC. }Conservancy

* *Multiple Employees from the same Employer on a PLC.* Conservancy

discourages the practice of having multiple employees of the same

employer serve on the same PLC\@. This practice increases the impact

employer serve on the same PLC. This practice increases the impact

of any prospective conflict of interest with the employer on the PLC,

...

@@ -224,14 +234,18 @@ are encouraged to err on the side of caution in identifying all potential

conflicts of interest relating to the employer.

\item \textbf{Conservancy is Final Arbiter.} Each PLC Person acknowledges

* *Conservancy is Final Arbiter.* Each PLC Person acknowledges

that Conservancy is the final arbiter of any issue relating to potential

conflict.

\item \textbf{Project Conflict Disclosure Form. }Each PLC Person shall complete

a Project Conflict Disclosure form {[}Attached as Exhibit B{]} and

* *Project Conflict Disclosure Form.* Each PLC Person shall complete

a Project Conflict Disclosure form <<Exhibit-B,Attached as Exhibit B>> and

submit it to the PLC and to Conservancy's Executive Director on an

annual basis.

\end{itemize}

\subsection{Conflict Resolution Procedures for PLC Persons}

\begin{itemize}

\item \textbf{Disclosure of Conflict When Present.} Prior to any PLC or

[[Procedures-PLC-Persons]]

=== Conflict Resolution Procedures for PLC Persons

* *Disclosure of Conflict When Present.* Prior to any PLC or

PLC sub-committee action on a matter or transaction involving a conflict

...

@@ -241,3 +255,4 @@ the conflict. Such disclosure shall be reflected in the minutes of

the meeting.

\item \textbf{Disclosure of Conflict When Absent. }A PLC Person who plans

* *Disclosure of Conflict When Absent.* A PLC Person who plans

not to attend a meeting at which he or she has reason to believe that

...

@@ -248,4 +263,5 @@ at the meeting and the disclosure shall be reflected in the minutes

of the meeting.

\item \textbf{Participation in Discussions and Votes Regarding Conflicted

Matter.} A conflicted PLC Person shall not participate in or be permitted

* *Participation in Discussions and Votes Regarding Conflicted Matter.*

A conflicted PLC Person shall not participate in or be permitted

to hear the PLC's or PLC sub-committee's discussion of the matter

...

@@ -255,3 +271,4 @@ not attempt to exert his or her personal influence with respect to

the matter, either at or outside the meeting.

\item \textbf{Participation in Votes Regarding Conflicted Matter.} A conflicted

* *Participation in Votes Regarding Conflicted Matter.* A conflicted

PLC Person may not vote on the Board action with which he or she has

...

@@ -260,8 +277,9 @@ a conflict of interest, and shall not be present in the meeting room

to vote shall be reflected in the minutes of the meeting.

\item \textbf{Conflicted Persons Cannot Establish Quorum.} A conflicted

* *Conflicted Persons Cannot Establish Quorum.* A conflicted

PLC Person shall not be determining the presence of a quorum for purposes

of a vote on the matter where he or she has a conflict of interest.

\end{itemize}

\subsection{Procedures for Conservancy Retaining PLC Person's Services}

=== Procedures for Conservancy Retaining PLC Person's Services

...

@@ -274,4 +292,4 @@ contract desired by Conservancy and/or a Project. To address those

instances, Conservancy requests Projects to follow the following procedures.

\begin{itemize}

\item \textbf{Drafting the Software Development Proposal.} PLCs must draft

* *Drafting the Software Development Proposal.* PLCs must draft

a written proposal for every software development project their Project

...

@@ -283,6 +301,7 @@ of interest and must recuse herself or himself from the proposal drafting

process and abstain from any vote to approve that proposal. All other

procedures as outlined in Section 3.3 shall still apply. The PLC must

procedures as outlined in <<Procedures-PLC-Persons,_Conflict Resolution Procedures for PLC Persons_>> shall still apply. The PLC must

document the PLC Person's abstention from the proposal drafting process

in the minutes of the next PLC meeting.

\item \textbf{Selecting a PLC Person to Fulfill a Contract. }Once a PLC

* *Selecting a PLC Person to Fulfill a Contract.* Once a PLC

has drafted and approved a development proposal, the PLC is free to

...

@@ -292,4 +311,3 @@ to carry out the work, the following criteria must be met:

\begin{itemize}

\item \textbf{Suggested Compensation.} The PLC must provide Conservancy's

** *Suggested Compensation.* The PLC must provide Conservancy's

Executive Director (or designee) with a suggested compensation (converted

...

@@ -297,3 +315,4 @@ into an hourly wage) for the software developer to be retained to

fulfill the funded contract.

\item \textbf{Independent Assessment of Credentials.} The PLC (or an unaffiliated

** *Independent Assessment of Credentials.* The PLC (or an unaffiliated

PLC Person) must provide Conservancy's Executive Director (or designee)

...

@@ -301,3 +320,4 @@ with a written assessment as to why the PLC Person is uniquely qualified

to fulfill the funded contract.

\item \textbf{Conservancy Retains Right to Request Competitive Bids.} PLCs

** *Conservancy Retains Right to Request Competitive Bids.* PLCs

acknowledge that Conservancy retains the right to ask for bids from

...

@@ -307,5 +327,5 @@ will consult with the PLC to select the candidate best suited to fulfill

the contract within the budget allotted.

\end{itemize}

\item \textbf{Conservancy holds Sole Authority to Negotiate and Execute

Contracts. }PLCs acknowledge that Conservancy holds sole authority

* *Conservancy holds Sole Authority to Negotiate and Execute Contracts.*

PLCs acknowledge that Conservancy holds sole authority

to negotiate and execute contracts on behalf of Member Projects. In

...

@@ -316,5 +336,5 @@ contractors - including PLC Persons - beyond collecting the terms

of the developer(s)' bid.

\end{itemize}

\section{Project Community Members: Participating Corporations and Volunteers}

== Project Community Members: Participating Corporations and Volunteers

...

@@ -326,4 +346,4 @@ considered to be ``interested persons,'' and all decision-making

authority rests with the PLCs and/or Conservancy.

\begin{itemize}

\item \textbf{Community Members Cannot Direct Funds.} Community Members

* *Community Members Cannot Direct Funds.* Community Members

are free to offer suggestions and engage in open dialogue with PLC,

...

@@ -334,6 +354,8 @@ Members who make financial donations do not receive any additional

control over a Project's technical direction beyond what is available

to other vocal, active, and contributing community members. \pagebreak{}

\end{itemize}

to other vocal, active, and contributing community members.

\section*{Exhibit A: Conservancy Conflict Disclosure Form}

[[Exhibit-A]]

== Exhibit A: Conservancy Conflict Disclosure Form

...

@@ -341,3 +363,3 @@ Directors, Officers and Staff Members of Conservancy each have a duty

to protect Conservancy and its Member Projects from violating state

and federal laws - and to avoid any appearance of impropriety. Conservancy

and federal laws -- and to avoid any appearance of impropriety. Conservancy

Persons serve the public interest and are to have a clear understanding

...

@@ -350,23 +372,26 @@ Chairperson of Conservancy's Board and to Conservancy's General Counsel.

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_

Date: +++__________________________+++

Next Form to be completed by (six months from now):

Next Form to be completed by (six months from now): \_\_\_\_\_\_\_\_\_\_\_

Name: +++__________________________+++

Name: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: +++__________________________+++

Position (employee/officer/trustee): \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Position (employee/officer/trustee): +++_________________________________+++

I affirm the following:

\begin{itemize}

\item I have received a copy of the Software Freedom Conservancy Conflict

of Interest Policy. \_\_\_\_\_\_\_\_\_ (initial)

\item I have read and understand the policy. \_\_\_\_\_\_\_\_\_ (initial)

\item I agree to comply with the policy. \_\_\_\_\_\_\_\_\_ (initial)

\item I understand that Conservancy is a public charity and in order to

* I have received a copy of the Software Freedom Conservancy Conflict

of Interest Policy. +++__________________+++ (initial)

* I have read and understand the policy. +++_________+++ (initial)

* I agree to comply with the policy. +++_________+++ (initial)

* I understand that Conservancy is a public charity and in order to

maintain its federal tax exemption it must engage primarily in activities

which accomplish one or more of tax-exempt purposes. \_\_\_\_\_\_\_\_\_

(initial)

\end{itemize}

Disclosures:

which accomplish one or more of tax-exempt purposes. +++_________+++ (initial)

.Disclosures:

...

@@ -378,16 +403,16 @@ or otherwise:

\_\_\_\_\_\_\_\_ I have no conflicts to report

+++________+++ I have no conflicts to report

\_\_\_\_\_\_\_\_ I have the following conflicts and/or potential conflicts

+++________+++ I have the following conflicts and/or potential conflicts

to report:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

...

@@ -396,8 +421,9 @@ to the best of my knowledge.

Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Signature: +++______________________________________+++

Date: +++_________________+++

\section*{\pagebreak{}Exhibit B: Project Leadership Committee Conflict Disclosure

Form}

[[Exhibit-B]]

== Exhibit B: Project Leadership Committee Conflict Disclosure Form

...

@@ -413,26 +439,28 @@ his or her PLC and to Conservancy's Executive Director.

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_

Date: +++_____________+++

Next Form to be completed by (one year from now): \_\_\_\_\_\_\_\_\_\_\_

Next Form to be completed by (one year from now): +++___________+++

Name: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name: +++____________________________________+++

Date: +++____________________+++

Position (if applicable): \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Position (if applicable): +++________________________________+++

Employer (if student or self-employed, please indicate): \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Employer (if student or self-employed, please indicate): +++________________________________+++

I affirm the following:

\begin{itemize}

\item I have received a copy of the Software Freedom Conservancy Conflict

of Interest Policy. \_\_\_\_\_\_\_\_\_ (initial)

\item I have read and understand the policy, in particular, Section 3 (relating

to PLCs). \_\_\_\_\_\_\_\_\_ (initial)

\item I agree to comply with the policy. \_\_\_\_\_\_\_\_\_ (initial)

\item I understand that Conservancy is a public charity and in order to

* I have received a copy of the Software Freedom Conservancy Conflict

of Interest Policy. +++_________+++ (initial)

* I have read and understand the policy, in particular, Section 3 (relating

to PLCs). +++_________+++ (initial)

* I agree to comply with the policy. +++_________+++ (initial)

* I understand that Conservancy is a public charity and in order to

maintain its federal tax exemption it must engage primarily in activities

which accomplish one or more of tax-exempt purposes. \_\_\_\_\_\_\_\_\_

(initial)

\end{itemize}

Disclosures:

which accomplish one or more of tax-exempt purposes. +++_________+++ (initial)

.Disclosures:

...

@@ -444,16 +472,16 @@ or otherwise:

\_\_\_\_\_\_\_\_ I have no conflicts to report

+++________+++ I have no conflicts to report

\_\_\_\_\_\_\_\_ I have the following conflicts and/or potential conflicts

+++________+++ I have the following conflicts and/or potential conflicts

to report:

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+++____________________________________________________________________________+++

...

@@ -462,4 +490,5 @@ to the best of my knowledge.

Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

\end{document}

Signature: +++________________________________________+++

Date: +++____________________________________+++