0 1 1
Brett Smith (brett) - 20 months ago 2019-03-12 14:24:36
brett@sfconservancy.org
Publish conflict-of-interest-policy.html revision d477e1b02e2093594db118aaa956da8c93129d58.
2 files changed with 498 insertions and 1 deletions:
↑ Collapse Diff ↑
 
new file 100644
1
 
{% extends "base_projects.html" %}
2
 
{% block subtitle %}Conflict of Interest Policy - {% endblock %}
3
 
{% block submenuselection %}Policies{% endblock %}
4
 
{% block content %}
5
 

	
6
 
<h1 id="software-freedom-conservancy-conflict-of-interest-policy">Software Freedom Conservancy Conflict of Interest Policy</h1>
7
 
<h2 id="purpose">Purpose</h2>
8
 
<p>The purpose of this conflict of interest policy (&ldquo;Policy&rdquo;)  is to protect
9
 
the Software Freedom Conservancy (&ldquo;Conservancy&rdquo;) and its Member Projects
10
 
when Conservancy contemplates entering into a transaction or arrangement
11
 
that might benefit the private interest of a Director, Officer or Staff
12
 
Member of Conservancy or a member of a Project Leadership Committee
13
 
(&ldquo;PLC&rdquo;), or might otherwise result in a possible excess benefit
14
 
transaction. This Policy is intended to supplement but not replace any
15
 
applicable state and federal laws governing conflict of interest
16
 
applicable to nonprofit and charitable organizations.</p>
17
 
<h2 id="conservancy-directors-officers-and-staff">Conservancy Directors, Officers and Staff</h2>
18
 
<p>Directors, Officers and Staff Members of Conservancy (&ldquo;Conservancy
19
 
Persons&rdquo;) each have a duty to protect Conservancy and its Member Projects
20
 
from violating New York State and USA federal &ndash; and to avoid any appearance of
21
 
impropriety. Conservancy Persons serve the public interest and are to have
22
 
a clear understanding of Conservancy&rsquo;s charitable mission. All decisions
23
 
made by Conservancy Persons are to be made solely on the basis of a desire
24
 
to promote the best interests of Conservancy and the public good.</p>
25
 
<h3 id="defining-a-conflict-of-interest-for-a-conservancy-person">Defining a Conflict of Interest for a Conservancy Person</h3>
26
 
<p>In general, Conservancy Persons should avoid making decisions on matters
27
 
where their personal interests are at odds with the Conservancy&rsquo;s
28
 
interests. In particular, the following scenarios are to be identified as
29
 
conflicts of interest:</p>
30
 
<ul>
31
 
<li>
32
 
<p>A Conservancy Person (or his or her family member) is a party to a
33
 
contract, or involved in a transaction with Conservancy for goods
34
 
or services.</p>
35
 
</li>
36
 
<li>
37
 
<p>A Conservancy Person (or his or her family member) is a director,
38
 
officer, agent, partner, associate, employee, trustee, personal
39
 
representative, receiver, guardian, custodian, legal representative or in
40
 
some other way has a fiduciary duty to an entity involved in a transaction
41
 
with Conservancy.</p>
42
 
</li>
43
 
<li>
44
 
<p>A Conservancy Person (or his or her family member) is engaged in a substantial
45
 
capacity or has a material financial interest in a for-profit enterprise
46
 
that competes with Conservancy or a Conservancy Project.</p>
47
 
</li>
48
 
<li>
49
 
<p>A Conservancy Person (or his or her family member) has a material
50
 
financial interest in, or fiduciary duty to an entity Conservancy
51
 
has engaged in a free software license compliance effort, enforcement
52
 
effort, or related litigation on behalf of a Conservancy project.</p>
53
 
</li>
54
 
<li>
55
 
<p>A Conservancy Person (or his or her family member) has a material
56
 
financial interest in or fiduciary duty to the competitor of an entity
57
 
Conservancy has engaged in a free software license compliance effort,
58
 
enforcement effort, or related litigation on behalf of a Conservancy
59
 
project.</p>
60
 
</li>
61
 
</ul>
62
 
<p>Conservancy acknowledges that other situations may create the appearance
63
 
of a conflict, or present a duality of interests. All such circumstances
64
 
should be disclosed to the Board, as appropriate, and the Board shall make
65
 
a decision as to what (if any) course of action Conservancy or relevant
66
 
Conservancy Persons should take so that Conservancy&rsquo;s best interests are
67
 
not compromised by personal interests.</p>
68
 
<h3 id="general-policies-for-conservancy-persons">General Policies for Conservancy Persons</h3>
69
 
<ul>
70
 
<li>
71
 
<p><strong>No Personal Profit or Gain.</strong> No Conservancy Person (or family
72
 
member) shall derive any personal profit or gain, directly or indirectly,
73
 
by reason of his or her participation with Conservancy. Personal profit
74
 
or gain does not include compensation approved by the Board for paid
75
 
employees, or reimbursement of legitimate Conservancy expenses.</p>
76
 
</li>
77
 
<li>
78
 
<p><strong>Disclosure and Abstention when Conflicted.</strong> Each Conservancy
79
 
Person shall disclose to Conservancy&rsquo;s Board any conflict of interest
80
 
which he or she may have in any matter pending before Conservancy
81
 
and shall refrain from participation in any decision on such matter.</p>
82
 
</li>
83
 
<li>
84
 
<p><strong>Conservancy Conflict Disclosure Form.</strong> Every six months, each
85
 
Conservancy Person shall complete a Conservancy Conflict Disclosure
86
 
form attached as Exhibit A and submit it to the Board and to
87
 
Conservancy&rsquo;s General Counsel.</p>
88
 
</li>
89
 
</ul>
90
 
<h3 id="conflict-resolution-procedures-for-conservancy-persons">Conflict Resolution Procedures for Conservancy Persons</h3>
91
 
<ul>
92
 
<li>
93
 
<p><strong>Disclosure of Conflict When Present.</strong> Prior to any Board or
94
 
Board Committee action on a matter or transaction involving a conflict
95
 
of interest, a Conservancy Person having a conflict of interest and
96
 
who is in attendance at the meeting shall disclose all facts material
97
 
to the conflict. Such disclosure shall be reflected in the minutes
98
 
of the meeting. If board members are aware that Staff or other volunteers
99
 
have a conflict of interest, relevant facts should be disclosed by
100
 
the board member or by the interested person him/herself if invited
101
 
to the Board meeting as a guest for purposes of disclosure.</p>
102
 
</li>
103
 
<li>
104
 
<p><strong>Disclosure of Conflict When Absent.</strong> A Conservancy Person
105
 
who plans not to attend a meeting at which he or she has reason to
106
 
believe that the Board or Board Committee will act on a matter in
107
 
which he or she is conflicted shall disclose to the Chair of the meeting
108
 
all facts material to the conflict of interest. The Chairperson shall
109
 
report the disclosure at the meeting and the disclosure shall be reflected
110
 
in the minutes of the meeting.</p>
111
 
</li>
112
 
<li>
113
 
<p><strong>Participation in Discussions and Votes Regarding Conflicted Matter.</strong>
114
 
On a matter in which a Conservancy Person has a conflict of interest, the
115
 
conflicted Conservancy Person must abstain from, and must not hear nor
116
 
read the pre-vote discussions of the matter by the Board or Board
117
 
Committee, except to disclose material facts and to respond to
118
 
questions. The conflicted Conservancy Person shall not attempt to exert
119
 
his or her personal influence with respect to the matter, either at or
120
 
outside the meeting.  The Conflicted Person may read minutes and/or
121
 
logs of the matter&rsquo;s discussion after voting is complete.</p>
122
 
</li>
123
 
<li>
124
 
<p><strong>Participation in Votes Regarding Conflicted Matter.</strong> A conflicted
125
 
Conservancy Person may not vote on the Board action with which he
126
 
or she has a conflict of interest, and shall not be present in the
127
 
meeting room (or on the conference call) when the vote is taken. His
128
 
or her ineligibility to vote shall be reflected in the minutes of
129
 
the meeting.</p>
130
 
</li>
131
 
<li>
132
 
<p><strong>Conflicted Persons Cannot Establish Quorum.</strong> A conflicted
133
 
Conservancy Person shall not be determining the presence of a quorum
134
 
for purposes of a vote on the matter where he or she has a conflict
135
 
of interest.</p>
136
 
</li>
137
 
<li>
138
 
<p><strong>Managing an Officer&rsquo;s Conflict of Interest.</strong> If a Conservancy
139
 
Person is an Officer involved in a decision, matter or transaction
140
 
in which he or she has a conflict of interest, he or she must immediately
141
 
disclose all facts material to the conflict to the Chair of the Board
142
 
(or the Chair&rsquo;s designee). The Board must then approve any future
143
 
decisions, negotiations, and/or other actions taken by the Officer
144
 
regarding the conflicted matter, and include the person&rsquo;s disclosure
145
 
of the conflict and the Board&rsquo;s subsequent actions in the minutes
146
 
of the next meeting.</p>
147
 
</li>
148
 
<li>
149
 
<p><strong>Managing a Staff Member&rsquo;s Conflict of Interest.</strong> If a Conservancy
150
 
Person is a Staff Member who has been assigned duties that involve
151
 
a decision, matter or transaction in which he or she has a conflict
152
 
of interest, he or she must immediately disclose all facts material
153
 
to the conflict to the President (or the President&rsquo;s designee). The
154
 
President (or designee) must then approve any future decisions, negotiations,
155
 
and/or other actions taken by the Staff Member regarding the conflicted
156
 
matter, and file a written report acknowledging the potential conflict.</p>
157
 
</li>
158
 
<li>
159
 
<p><strong>Confidentiality of Conflict Disclosures.</strong> Each Conservancy
160
 
Person shall exercise care not to disclose confidential information
161
 
acquired in connection with disclosures of conflicts of interest or
162
 
potential conflicts, which might be adverse to Conservancy&rsquo;s interests.</p>
163
 
</li>
164
 
</ul>
165
 
<h2 id="project-leadership-committees">Project Leadership Committees</h2>
166
 
<p>PLCs are comprised of volunteers, academics, and industry professionals
167
 
that represent a Project&rsquo;s community and make decisions about a Project&rsquo;s
168
 
technical direction (&ldquo;PLC Persons&rdquo;). Conservancy understands and
169
 
expects that many PLC Persons exploit professional skills relating
170
 
to their Project as individuals by providing developing, consulting,
171
 
and/or training services. Nonetheless, each PLC Person has a duty
172
 
to act in the best interests of his or her Project when making technical
173
 
decisions about the Project.</p>
174
 
<h3 id="defining-a-conflict-of-interest-for-a-plc-person">Defining a Conflict of Interest for a PLC Person</h3>
175
 
<p>In general, PLC Persons should avoid making technical decisions on
176
 
matters where his or her personal and/or professional interests are
177
 
at odds with his or her Project&rsquo;s interests. In particular, the following
178
 
scenarios are to be identified as conflicts of interest:</p>
179
 
<ul>
180
 
<li>
181
 
<p>A PLC Person (or his or her family member) is a party to a contract,
182
 
or involved in a transaction with Conservancy for goods or services
183
 
relating to his or her Project.</p>
184
 
</li>
185
 
<li>
186
 
<p>A PLC Person (or his or her family member) is an employee, owner,
187
 
or otherwise has a financial interest in an entity involved in a transaction
188
 
with Conservancy relating to his or her Project.</p>
189
 
</li>
190
 
<li>
191
 
<p>A PLC Person (or his or her family member) is a director, officer,
192
 
agent, partner, associate, trustee, receiver, guardian, personal representative,
193
 
custodian, legal representative or in some way has a fiduciary duty
194
 
to an entity involved in a transaction with Conservancy relating to
195
 
his or her Project.</p>
196
 
</li>
197
 
<li>
198
 
<p>A PLC Person (or his or her family member) is engaged in a substantial capacity
199
 
or has a material financial interest in a for-profit enterprise that
200
 
competes with his or her Project.</p>
201
 
</li>
202
 
<li>
203
 
<p>A PLC Person (or his or her family member) is the owner of copyrights
204
 
that are the subject of a Conservancy-led compliance effort, enforcement
205
 
effort, or related litigation &ndash; and the PLC Person (or a family member)
206
 
has a material financial interest in or fiduciary duty to an entity
207
 
adverse to this effort.</p>
208
 
</li>
209
 
</ul>
210
 
<p>Conservancy further notes that a scenario may arise where a PLC Person
211
 
(or his or her family member) works for, owns, or otherwise has a
212
 
financial interest in an entity that competes with a second entity
213
 
involved in a transaction with Conservancy regarding the Project in
214
 
question. This may or may not result in a conflict of interest, depending
215
 
on the specific facts. Should this scenario arise, Conservancy requests
216
 
that the circumstances be disclosed to Conservancy&rsquo;s Executive Director
217
 
and to the PLC.</p>
218
 
<p>Conservancy acknowledges that other situations may create the appearance
219
 
of a conflict, or present a duality of interests. All such circumstances
220
 
should be disclosed to Conservancy&rsquo;s Executive Director and to the
221
 
PLC, as appropriate, and the PLC shall make a decision as to what
222
 
(if any) course of action the PLC or relevant PLC Persons should take
223
 
so that the Project&rsquo;s best interests are not compromised by personal
224
 
interests.</p>
225
 
<h3 id="general-policies-for-plc-persons">General Policies for PLC Persons</h3>
226
 
<ul>
227
 
<li>
228
 
<p><strong>No Compensation for PLC Persons.</strong> No PLC Person shall receive any
229
 
salary or other substantial benefit from Conservancy as compensation for his
230
 
or her duties as a PLC Person.  Compensation does not include reimbursement
231
 
of legitimate Project expenses.</p>
232
 
</li>
233
 
<li>
234
 
<p><strong>Disclosure and Abstention when Conflicted.</strong> Each PLC Person
235
 
shall disclose to his or her PLC and to Conservancy&rsquo;s Executive Director
236
 
any conflict of interest which he or she may have in any matter pending
237
 
before the PLC and shall refrain from participation in any decision
238
 
on such matter.</p>
239
 
</li>
240
 
<li>
241
 
<p><strong>Multiple Employees from the same Employer on a PLC.</strong> Conservancy
242
 
discourages the practice of having multiple employees of the same
243
 
employer serve on the same PLC. This practice increases the impact
244
 
of any prospective conflict of interest with the employer on the PLC,
245
 
and PLCs will have to exercise greater care to avoid the influence
246
 
of the employer&rsquo;s interests. If this situation is unavoidable, PLCs
247
 
are encouraged to err on the side of caution in identifying all potential
248
 
conflicts of interest relating to the employer.</p>
249
 
</li>
250
 
<li>
251
 
<p><strong>Conservancy is Final Arbiter.</strong> Each PLC Person acknowledges
252
 
that Conservancy is the final arbiter of any issue relating to potential
253
 
conflict.</p>
254
 
</li>
255
 
<li>
256
 
<p><strong>Project Conflict Disclosure Form.</strong> Each PLC Person shall complete
257
 
a Project Conflict Disclosure form attached as Exhibit B and
258
 
submit it to the PLC and to Conservancy&rsquo;s Executive Director on an
259
 
annual basis.</p>
260
 
</li>
261
 
</ul>
262
 
<h3 id="conflict-resolution-procedures-for-plc-persons">Conflict Resolution Procedures for PLC Persons</h3>
263
 
<ul>
264
 
<li>
265
 
<p><strong>Disclosure of Conflict When Present.</strong> Prior to any PLC or
266
 
PLC sub-committee action on a matter or transaction involving a conflict
267
 
of interest, a PLC Person having a conflict of interest and who is
268
 
in attendance at the meeting shall disclose all facts material to
269
 
the conflict. Such disclosure shall be reflected in the minutes of
270
 
the meeting.</p>
271
 
</li>
272
 
<li>
273
 
<p><strong>Disclosure of Conflict When Absent.</strong> A PLC Person who plans
274
 
not to attend a meeting at which he or she has reason to believe that
275
 
the PLC or PLC sub-committee will act on a matter in which he or she
276
 
is conflicted shall disclose to the Chair of the meeting all facts
277
 
material to the conflict of interest. The Chair shall report the disclosure
278
 
at the meeting and the disclosure shall be reflected in the minutes
279
 
of the meeting.</p>
280
 
</li>
281
 
<li>
282
 
<p><strong>Participation in Discussions and Votes Regarding Conflicted Matter.</strong>
283
 
On a matter in which a PLC Person has a conflict of interest, the
284
 
conflicted PLC Person must abstain from, and must not hear nor
285
 
read the pre-vote discussions of the matter by the PLC or PLC
286
 
sub-committee, except to disclose material facts and to respond to
287
 
questions. The conflicted PLC Person shall not attempt to exert
288
 
his or her personal influence with respect to the matter, either at or
289
 
outside the meeting.  The conflicted PLC Person may read minutes and/or
290
 
logs of the matter&rsquo;s discussion after voting is complete.</p>
291
 
</li>
292
 
<li>
293
 
<p><strong>Participation in Votes Regarding Conflicted Matter.</strong> A conflicted
294
 
PLC Person may not vote on the PLC action with which he or she has
295
 
a conflict of interest, and shall not be present in the meeting room
296
 
(or on the conference call) when the vote is taken. His or her ineligibility
297
 
to vote shall be reflected in the minutes of the meeting.</p>
298
 
</li>
299
 
<li>
300
 
<p><strong>Conflicted Persons Cannot Establish Quorum.</strong> A conflicted
301
 
PLC Person shall not be determining the presence of a quorum for purposes
302
 
of a vote on the matter where he or she has a conflict of interest.</p>
303
 
</li>
304
 
</ul>
305
 
<h3 id="procedures-for-conservancy-retaining-plc-persons-services">Procedures for Conservancy Retaining PLC Person&rsquo;s Services</h3>
306
 
<p>Notwithstanding the above, Conservancy acknowledges that many PLC
307
 
Persons are technical service contractors (e.g., software developers,
308
 
documentation writers, website developers, etc.) who can provide professional
309
 
services useful to advance computing and contribute to Conservancy&rsquo;s mission.
310
 
In many instances, a PLC Person will have the strongest mix of credentials,
311
 
experience, and interest and availability to fulfill a technical service
312
 
contract desired by Conservancy and/or a Project. To address those
313
 
instances, Conservancy requests Projects to follow the following procedures.</p>
314
 
<ul>
315
 
<li>
316
 
<p><strong>Drafting the Technical Service Proposal.</strong> PLCs must draft
317
 
a written proposal for every technical service project their Project
318
 
wishes to fund. During the drafting process, if a PLC Person (or his
319
 
or her family member), a PLC Person&rsquo;s employer and/or a fellow employee
320
 
of PLC Person&rsquo;s employer wish to be considered a candidate to fulfill
321
 
the funded technical service contract, that PLC Person has a conflict
322
 
of interest and must recuse herself or himself from the proposal drafting
323
 
process, except to disclose material facts and to respond to questions,
324
 
and must abstain from any vote to approve that proposal.  All other
325
 
procedures as outlined in
326
 
<a href="#conflict-resolution-procedures-for-plc-persons">Conflict Resolution Procedures for PLC Persons</a>
327
 
shall still apply. The PLC must document the PLC Person&rsquo;s abstention from the
328
 
proposal drafting process in the minutes of the next PLC meeting.</p>
329
 
</li>
330
 
<li>
331
 
<p><strong>Selecting a PLC Person to Fulfill a Contract.</strong> Once a PLC
332
 
has drafted and approved a technical service proposal, the PLC is free to
333
 
consider qualified candidates to fulfill the funded contract. If the
334
 
PLC wishes to recommend that Conservancy contract with a PLC Person
335
 
to carry out the work, the following criteria must be met:</p>
336
 
</li>
337
 
<li>
338
 
<p><strong>Suggested Compensation.</strong> The PLC must provide Conservancy&rsquo;s
339
 
Executive Director (or designee) with a suggested compensation (converted
340
 
into an hourly wage) for the technical service contractor to be retained to
341
 
fulfill the funded contract.</p>
342
 
</li>
343
 
<li>
344
 
<p><strong>Independent Assessment of Credentials.</strong> The PLC (or an unaffiliated
345
 
PLC Person) must provide Conservancy&rsquo;s Executive Director (or designee)
346
 
with a written assessment as to why the PLC Person is uniquely qualified
347
 
to fulfill the funded contract.</p>
348
 
</li>
349
 
<li>
350
 
<p><strong>Conservancy Retains Right to Request Competitive Bids.</strong> PLCs
351
 
acknowledge that Conservancy retains the right to ask for bids from
352
 
technical service contractors in addition to PLC Person to fulfill a given contract.
353
 
Should that instance arise, Conservancy&rsquo;s Executive Director (or designee)
354
 
will consult with the PLC to select the candidate best suited to fulfill
355
 
the contract within the budget allotted.</p>
356
 
</li>
357
 
<li>
358
 
<p><strong>Conservancy holds Sole Authority to Negotiate and Execute Contracts.</strong>
359
 
PLCs acknowledge that Conservancy holds sole authority
360
 
to negotiate and execute contracts on behalf of Member Projects. In
361
 
turn, Conservancy pledges to negotiate all contracts zealously, putting
362
 
the best interests of the affected Member Project first. To avoid
363
 
any conflicts, PLCs must not engage in any pre-negotiation with prospective
364
 
technical service contractors &ndash; including PLC Persons &ndash; beyond collecting the terms
365
 
of the technical service contractor(s)&rsquo; bid.</p>
366
 
</li>
367
 
</ul>
368
 
<h2 id="project-community-members-participating-corporations-and-volunteers">Project Community Members: Participating Corporations and Volunteers</h2>
369
 
<p>The work accomplished by Conservancy and its Member Projects would
370
 
not be possible without the generous donation of time, funds, and
371
 
support Project Community Members &ndash; including participating corporations,
372
 
sponsors, and volunteers alike. Community members are not traditionally
373
 
considered to be &ldquo;interested persons,&rdquo; and all decision-making
374
 
authority rests with the PLCs and/or Conservancy.</p>
375
 
<ul>
376
 
<li><strong>Community Members Cannot Direct Funds.</strong> Community Members
377
 
are free to offer suggestions and engage in open dialogue with PLCs and/or
378
 
key developers and architects regarding a Project&rsquo;s technical direction. However,
379
 
each PLC and Conservancy must together maintain sole and final control
380
 
over that Project&rsquo;s technical direction and charitable mission. Community
381
 
Members who make financial donations do not receive any additional
382
 
control over a Project&rsquo;s technical direction beyond what is available
383
 
to other vocal, active, and contributing community members.</li>
384
 
</ul>
385
 
<h2 id="exhibit-a-conservancy-conflict-disclosure-form">Exhibit A: Conservancy Conflict Disclosure Form</h2>
386
 
<p>Directors, Officers and Staff Members of Conservancy each have a duty
387
 
to protect Conservancy and its Member Projects from violating state
388
 
and federal laws &ndash; and to avoid any appearance of impropriety. Conservancy
389
 
Persons serve the public interest and are to have a clear understanding
390
 
of Conservancy&rsquo;s charitable mission. All decisions made by Conservancy
391
 
Persons are to be made solely on the basis of a desire to promote
392
 
the best interests of Conservancy and the public good.</p>
393
 
<p>This Form is to be completed every six months and submitted to the
394
 
Chairperson of Conservancy&rsquo;s Board and to Conservancy&rsquo;s General Counsel.</p>
395
 
<p>Date: <code>__________________________</code></p>
396
 
<p>Next Form to be completed by (six months from now): <code>__________________</code></p>
397
 
<p>Name: <code>__________________________</code></p>
398
 
<p>Position (employee/officer/trustee): <code>_________________________________</code></p>
399
 
<p>I affirm the following:</p>
400
 
<ul>
401
 
<li>
402
 
<p>I have received a copy of the Software Freedom Conservancy Conflict
403
 
of Interest Policy. <code>__________________</code> (initial)</p>
404
 
</li>
405
 
<li>
406
 
<p>I have read and understand the policy. <code>_________</code> (initial)</p>
407
 
</li>
408
 
<li>
409
 
<p>I agree to comply with the policy. <code>_________</code> (initial)</p>
410
 
</li>
411
 
<li>
412
 
<p>I understand that Conservancy is a public charity and in order to
413
 
maintain its federal tax exemption it must engage primarily in activities
414
 
which accomplish one or more of tax-exempt purposes. <code>_________</code> (initial)</p>
415
 
</li>
416
 
</ul>
417
 
<p>Disclosures:</p>
418
 
<p>Please describe below any relationships, transactions, positions you
419
 
(or your family member) hold, or any other circumstances that you
420
 
believe could cause a conflict of interest as defined by the Policy
421
 
between your duty to Conservancy and your personal interests, financial
422
 
or otherwise:</p>
423
 
<p><code>________</code> I have no conflicts to report</p>
424
 
<p><code>________</code> I have the following conflicts and/or potential conflicts
425
 
to report:</p>
426
 
<pre><code>__________________________________________________________________________
427
 

	
428
 
__________________________________________________________________________
429
 

	
430
 
__________________________________________________________________________
431
 

	
432
 
__________________________________________________________________________
433
 

	
434
 
__________________________________________________________________________
435
 
</code></pre>
436
 
<p>I hereby certify that the information set forth is true and complete
437
 
to the best of my knowledge.</p>
438
 
<p>Signature: <code>______________________________________</code></p>
439
 
<p>Date: <code>_________________</code></p>
440
 
<h2 id="exhibit-b-project-leadership-committee-conflict-disclosure-form">Exhibit B: Project Leadership Committee Conflict Disclosure Form</h2>
441
 
<p>Each volunteer, academic and/or industry professional that serves
442
 
on a Conservancy Member Project&rsquo;s Project Leadership Committee (PLC)
443
 
have a duty to act in the best interests of his or her Project when
444
 
making decisions about the Project&rsquo;s technical direction. Every committee
445
 
member must also abide by New York State and USA federal laws associated with non-profit
446
 
organizational governance.</p>
447
 
<p>Committee members must complete this form annually and submit it to
448
 
his or her PLC and to Conservancy&rsquo;s Executive Director.</p>
449
 
<p>Date: <code>_____________</code></p>
450
 
<p>Next Form to be completed by (one year from now): <code>___________</code></p>
451
 
<p>Name: <code>____________________________________</code></p>
452
 
<p>Position (if applicable): <code>________________________________</code></p>
453
 
<p>Employer (if student or self-employed, please indicate): <code>________________________________</code></p>
454
 
<p>I affirm the following:</p>
455
 
<ul>
456
 
<li>
457
 
<p>I have received a copy of the Software Freedom Conservancy Conflict
458
 
of Interest Policy. <code>_________</code> (initial)</p>
459
 
</li>
460
 
<li>
461
 
<p>I have read and understand the policy, in particular, Section 3 (relating
462
 
to PLCs). <code>_________</code> (initial)</p>
463
 
</li>
464
 
<li>
465
 
<p>I agree to comply with the policy. <code>_________</code> (initial)</p>
466
 
</li>
467
 
<li>
468
 
<p>I understand that Conservancy is a public charity and in order to
469
 
maintain its federal tax exemption it must engage primarily in activities
470
 
which accomplish one or more of tax-exempt purposes. <code>_________</code> (initial)</p>
471
 
</li>
472
 
</ul>
473
 
<p>Disclosures:</p>
474
 
<p>Please describe below any relationships, transactions, positions you
475
 
(or your family member) hold, or any other circumstances that you
476
 
believe could cause a conflict of interest as defined by the Policy
477
 
between your duty to your Project and your personal interests, financial
478
 
or otherwise:</p>
479
 
<p><code>________</code> I have no conflicts to report</p>
480
 
<p><code>________</code> I have the following conflicts and/or potential conflicts
481
 
to report:</p>
482
 
<pre><code>__________________________________________________________________________
483
 

	
484
 
__________________________________________________________________________
485
 

	
486
 
__________________________________________________________________________
487
 

	
488
 
__________________________________________________________________________
489
 

	
490
 
__________________________________________________________________________
491
 
</code></pre>
492
 
<p>I hereby certify that the information set forth is true and complete
493
 
to the best of my knowledge.</p>
494
 
<p>Signature: <code>________________________________________</code></p>
495
 
<p>Date: <code>____________________________________</code></p>
496
 

	
497
 
{% endblock %}
1
 
conflict-of-interest-policy.9ed5723d4fa0cd23ff52a8945bd8b82d0b80b590.html
...
 
 No newline at end of file
1
 
conflict-of-interest-policy.d477e1b02e2093594db118aaa956da8c93129d58.html
...
 
 No newline at end of file
0 comments (0 inline, 0 general)