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{% extends "base_projects.html" %}
 
{% block subtitle %}Conflict of Interest Policy - {% endblock %}
 
{% block submenuselection %}Policies{% endblock %}
 
{% block content %}
 

	
 
<h1 id="software-freedom-conservancy-conflict-of-interest-policy">Software Freedom Conservancy Conflict of Interest Policy</h1>
 
<h2 id="purpose">Purpose</h2>
 
<p>The purpose of this conflict of interest policy (&ldquo;Policy&rdquo;)  is to protect
 
the Software Freedom Conservancy (&ldquo;Conservancy&rdquo;) 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
 
(&ldquo;PLC&rdquo;), 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.</p>
 
<h2 id="conservancy-directors-officers-and-staff">Conservancy Directors, Officers and Staff</h2>
 
<p>Directors, Officers and Staff Members of Conservancy (&ldquo;Conservancy
 
Persons&rdquo;) each have a duty to protect Conservancy and its Member Projects
 
from violating New York State and USA federal &ndash; and to avoid any appearance of
 
impropriety. Conservancy Persons serve the public interest and are to have
 
a clear understanding of Conservancy&rsquo;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.</p>
 
<h3 id="defining-a-conflict-of-interest-for-a-conservancy-person">Defining a Conflict of Interest for a Conservancy Person</h3>
 
<p>In general, Conservancy Persons should avoid making decisions on matters
 
where their personal interests are at odds with the Conservancy&rsquo;s
 
interests. In particular, the following scenarios are to be identified as
 
conflicts of interest:</p>
 
<ul>
 
<li>
 
<p>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.</p>
 
</li>
 
<li>
 
<p>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.</p>
 
</li>
 
<li>
 
<p>A Conservancy Person (or his or her family member) is engaged in a substantial
 
capacity or has a material financial interest in a for-profit enterprise
 
that competes with Conservancy or a Conservancy Project.</p>
 
</li>
 
<li>
 
<p>A Conservancy Person (or his or her family member) has a material
 
financial interest in, or fiduciary duty to an entity Conservancy
 
has engaged in a free software license compliance effort, enforcement
 
effort, or related litigation on behalf of a Conservancy project.</p>
 
</li>
 
<li>
 
<p>A Conservancy Person (or his or her family member) has a material
 
financial interest in or fiduciary duty to the competitor of an entity
 
Conservancy has engaged in a free software license compliance effort,
 
enforcement effort, or related litigation on behalf of a Conservancy
 
project.</p>
 
</li>
 
</ul>
 
<p>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&rsquo;s best interests are
 
not compromised by personal interests.</p>
 
<h3 id="general-policies-for-conservancy-persons">General Policies for Conservancy Persons</h3>
 
<ul>
 
<li>
 
<p><strong>No Personal Profit or Gain.</strong> No Conservancy Person (or family
 
member) shall derive any personal profit or gain, directly or indirectly,
 
by reason of his or her participation with Conservancy. Personal profit
 
or gain does not include compensation approved by the Board for paid
 
employees, or reimbursement of legitimate Conservancy expenses.</p>
 
</li>
 
<li>
 
<p><strong>Disclosure and Abstention when Conflicted.</strong> Each Conservancy
 
Person shall disclose to Conservancy&rsquo;s Board any conflict of interest
 
which he or she may have in any matter pending before Conservancy
 
and shall refrain from participation in any decision on such matter.</p>
 
</li>
 
<li>
 
<p><strong>Conservancy Conflict Disclosure Form.</strong> 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
 
Conservancy&rsquo;s General Counsel.</p>
 
</li>
 
</ul>
 
<h3 id="conflict-resolution-procedures-for-conservancy-persons">Conflict Resolution Procedures for Conservancy Persons</h3>
 
<ul>
 
<li>
 
<p><strong>Disclosure of Conflict When Present.</strong> Prior to any Board or
 
Board Committee action on a matter or transaction involving a conflict
 
of interest, a Conservancy Person having a conflict of interest and
 
who is in attendance at the meeting shall disclose all facts material
 
to the conflict. Such disclosure shall be reflected in the minutes
 
of the meeting. If board members are aware that Staff or other volunteers
 
have a conflict of interest, relevant facts should be disclosed by
 
the board member or by the interested person him/herself if invited
 
to the Board meeting as a guest for purposes of disclosure.</p>
 
</li>
 
<li>
 
<p><strong>Disclosure of Conflict When Absent.</strong> A Conservancy Person
 
who plans not to attend a meeting at which he or she has reason to
 
believe that the Board or Board Committee will act on a matter in
 
which he or she is conflicted shall disclose to the Chair of the meeting
 
all facts material to the conflict of interest. The Chairperson shall
 
report the disclosure at the meeting and the disclosure shall be reflected
 
in the minutes of the meeting.</p>
 
</li>
 
<li>
 
<p><strong>Participation in Discussions and Votes Regarding Conflicted Matter.</strong>
 
On a matter in which a Conservancy Person has a conflict of interest, the
 
conflicted Conservancy Person must abstain from, and must not hear nor
 
read the pre-vote discussions of the matter by the Board or Board
 
Committee, except to disclose material facts and to respond to
 
questions. The conflicted Conservancy Person shall not attempt to exert
 
his or her personal influence with respect to the matter, either at or
 
outside the meeting.  The Conflicted Person may read minutes and/or
 
logs of the matter&rsquo;s discussion after voting is complete.</p>
 
</li>
 
<li>
 
<p><strong>Participation in Votes Regarding Conflicted Matter.</strong> A conflicted
 
Conservancy Person may not vote on the Board action with which he
 
or she has a conflict of interest, and shall not be present in the
 
meeting room (or on the conference call) when the vote is taken. His
 
or her ineligibility to vote shall be reflected in the minutes of
 
the meeting.</p>
 
</li>
 
<li>
 
<p><strong>Conflicted Persons Cannot Establish Quorum.</strong> A conflicted
 
Conservancy 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.</p>
 
</li>
 
<li>
 
<p><strong>Managing an Officer&rsquo;s Conflict of Interest.</strong> If a Conservancy
 
Person is an Officer involved in a decision, matter or transaction
 
in which he or she has a conflict of interest, he or she must immediately
 
disclose all facts material to the conflict to the Chair of the Board
 
(or the Chair&rsquo;s designee). The Board must then approve any future
 
decisions, negotiations, and/or other actions taken by the Officer
 
regarding the conflicted matter, and include the person&rsquo;s disclosure
 
of the conflict and the Board&rsquo;s subsequent actions in the minutes
 
of the next meeting.</p>
 
</li>
 
<li>
 
<p><strong>Managing a Staff Member&rsquo;s Conflict of Interest.</strong> If a Conservancy
 
Person is a Staff Member who has been assigned duties that involve
 
a decision, matter or transaction in which he or she has a conflict
 
of interest, he or she must immediately disclose all facts material
 
to the conflict to the President (or the President&rsquo;s designee). The
 
President (or designee) must then approve any future decisions, negotiations,
 
and/or other actions taken by the Staff Member regarding the conflicted
 
matter, and file a written report acknowledging the potential conflict.</p>
 
</li>
 
<li>
 
<p><strong>Confidentiality of Conflict Disclosures.</strong> Each Conservancy
 
Person shall exercise care not to disclose confidential information
 
acquired in connection with disclosures of conflicts of interest or
 
potential conflicts, which might be adverse to Conservancy&rsquo;s interests.</p>
 
</li>
 
</ul>
 
<h2 id="project-leadership-committees">Project Leadership Committees</h2>
 
<p>PLCs are comprised of volunteers, academics, and industry professionals
 
that represent a Project&rsquo;s community and make decisions about a Project&rsquo;s
 
technical direction (&ldquo;PLC Persons&rdquo;). Conservancy understands and
 
expects that many PLC Persons exploit professional skills relating
 
to their Project as individuals by providing developing, consulting,
 
and/or training services. Nonetheless, each PLC Person has a duty
 
to act in the best interests of his or her Project when making technical
 
decisions about the Project.</p>
 
<h3 id="defining-a-conflict-of-interest-for-a-plc-person">Defining a Conflict of Interest for a PLC Person</h3>
 
<p>In general, PLC Persons should avoid making technical decisions on
 
matters where his or her personal and/or professional interests are
 
at odds with his or her Project&rsquo;s interests. In particular, the following
 
scenarios are to be identified as conflicts of interest:</p>
 
<ul>
 
<li>
 
<p>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.</p>
 
</li>
 
<li>
 
<p>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.</p>
 
</li>
 
<li>
 
<p>A PLC Person (or his or her family member) is a director, officer,
 
agent, partner, associate, trustee, receiver, guardian, personal representative,
 
custodian, legal representative or in some way has a fiduciary duty
 
to an entity involved in a transaction with Conservancy relating to
 
his or her Project.</p>
 
</li>
 
<li>
 
<p>A PLC Person (or his or her family member) is engaged in a substantial capacity
 
or has a material financial interest in a for-profit enterprise that
 
competes with his or her Project.</p>
 
</li>
 
<li>
 
<p>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
 
effort, or related litigation &ndash; and the PLC Person (or a family member)
 
has a material financial interest in or fiduciary duty to an entity
 
adverse to this effort.</p>
 
</li>
 
</ul>
 
<p>Conservancy further notes that a scenario may arise where a PLC Person
 
(or his or her family member) works for, owns, or otherwise has a
 
financial interest in an entity that competes with a second entity
 
involved in a transaction with Conservancy regarding the Project in
 
question. This may or may not result in a conflict of interest, depending
 
on the specific facts. Should this scenario arise, Conservancy requests
 
that the circumstances be disclosed to Conservancy&rsquo;s Executive Director
 
and to the PLC.</p>
 
<p>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 Conservancy&rsquo;s Executive Director and to the
 
PLC, as appropriate, and the PLC shall make a decision as to what
 
(if any) course of action the PLC or relevant PLC Persons should take
 
so that the Project&rsquo;s best interests are not compromised by personal
 
interests.</p>
 
<h3 id="general-policies-for-plc-persons">General Policies for PLC Persons</h3>
 
<ul>
 
<li>
 
<p><strong>No Compensation for PLC Persons.</strong> No PLC Person shall receive any
 
salary or other substantial benefit from Conservancy as compensation for his
 
or her duties as a PLC Person.  Compensation does not include reimbursement
 
of legitimate Project expenses.</p>
 
</li>
 
<li>
 
<p><strong>Disclosure and Abstention when Conflicted.</strong> Each PLC Person
 
shall disclose to his or her PLC and to Conservancy&rsquo;s Executive Director
 
any conflict of interest which he or she may have in any matter pending
 
before the PLC and shall refrain from participation in any decision
 
on such matter.</p>
 
</li>
 
<li>
 
<p><strong>Multiple Employees from the same Employer on a PLC.</strong> Conservancy
 
discourages the practice of having multiple employees of the same
 
employer serve on the same PLC. This practice increases the impact
 
of any prospective conflict of interest with the employer on the PLC,
 
and PLCs will have to exercise greater care to avoid the influence
 
of the employer&rsquo;s interests. If this situation is unavoidable, PLCs
 
are encouraged to err on the side of caution in identifying all potential
 
conflicts of interest relating to the employer.</p>
 
</li>
 
<li>
 
<p><strong>Conservancy is Final Arbiter.</strong> Each PLC Person acknowledges
 
that Conservancy is the final arbiter of any issue relating to potential
 
conflict.</p>
 
</li>
 
<li>
 
<p><strong>Project Conflict Disclosure Form.</strong> Each PLC Person shall complete
 
a Project Conflict Disclosure form attached as Exhibit B and
 
submit it to the PLC and to Conservancy&rsquo;s Executive Director on an
 
annual basis.</p>
 
</li>
 
</ul>
 
<h3 id="conflict-resolution-procedures-for-plc-persons">Conflict Resolution Procedures for PLC Persons</h3>
 
<ul>
 
<li>
 
<p><strong>Disclosure of Conflict When Present.</strong> Prior to any PLC or
 
PLC sub-committee action on a matter or transaction involving a conflict
 
of interest, a PLC Person having a conflict of interest and who is
 
in attendance at the meeting shall disclose all facts material to
 
the conflict. Such disclosure shall be reflected in the minutes of
 
the meeting.</p>
 
</li>
 
<li>
 
<p><strong>Disclosure of Conflict When Absent.</strong> A PLC Person who plans
 
not to attend a meeting at which he or she has reason to believe that
 
the PLC or PLC sub-committee will act on a matter in which he or she
 
is conflicted shall disclose to the Chair of the meeting all facts
 
material to the conflict of interest. The Chair shall report the disclosure
 
at the meeting and the disclosure shall be reflected in the minutes
 
of the meeting.</p>
 
</li>
 
<li>
 
<p><strong>Participation in Discussions and Votes Regarding Conflicted Matter.</strong>
 
On a matter in which a PLC Person has a conflict of interest, the
 
conflicted PLC Person must abstain from, and must not hear nor
 
read the pre-vote discussions of the matter by the PLC or PLC
 
sub-committee, except to disclose material facts and to respond to
 
questions. The conflicted PLC Person shall not attempt to exert
 
his or her personal influence with respect to the matter, either at or
 
outside the meeting.  The conflicted PLC Person may read minutes and/or
 
logs of the matter&rsquo;s discussion after voting is complete.</p>
 
</li>
 
<li>
 
<p><strong>Participation in Votes Regarding Conflicted Matter.</strong> A conflicted
 
PLC Person may not vote on the PLC action with which he or she has
 
a conflict of interest, and shall not be present in the meeting room
 
(or on the conference call) when the vote is taken. His or her ineligibility
 
to vote shall be reflected in the minutes of the meeting.</p>
 
</li>
 
<li>
 
<p><strong>Conflicted Persons Cannot Establish Quorum.</strong> 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.</p>
 
</li>
 
</ul>
 
<h3 id="procedures-for-conservancy-retaining-plc-persons-services">Procedures for Conservancy Retaining PLC Person&rsquo;s Services</h3>
 
<p>Notwithstanding the above, Conservancy acknowledges that many PLC
 
Persons are technical service contractors (e.g., software developers,
 
documentation writers, website developers, etc.) who can provide professional
 
services useful to advance computing and contribute to Conservancy&rsquo;s mission.
 
In many instances, a PLC Person will have the strongest mix of credentials,
 
experience, and interest and availability to fulfill a technical service
 
contract desired by Conservancy and/or a Project. To address those
 
instances, Conservancy requests Projects to follow the following procedures.</p>
 
<ul>
 
<li>
 
<p><strong>Drafting the Technical Service Proposal.</strong> PLCs must draft
 
a written proposal for every technical service project their Project
 
wishes to fund. During the drafting process, if a PLC Person (or his
 
or her family member), a PLC Person&rsquo;s employer and/or a fellow employee
 
of PLC Person&rsquo;s employer wish to be considered a candidate to fulfill
 
the funded technical service contract, that PLC Person has a conflict
 
of interest and must recuse herself or himself from the proposal drafting
 
process, except to disclose material facts and to respond to questions,
 
and must abstain from any vote to approve that proposal.  All other
 
procedures as outlined in
 
<a href="#conflict-resolution-procedures-for-plc-persons">Conflict Resolution Procedures for PLC Persons</a>
 
shall still apply. The PLC must document the PLC Person&rsquo;s abstention from the
 
proposal drafting process in the minutes of the next PLC meeting.</p>
 
</li>
 
<li>
 
<p><strong>Selecting a PLC Person to Fulfill a Contract.</strong> Once a PLC
 
has drafted and approved a technical service proposal, the PLC is free to
 
consider qualified candidates to fulfill the funded contract. If the
 
PLC wishes to recommend that Conservancy contract with a PLC Person
 
to carry out the work, the following criteria must be met:</p>
 
</li>
 
<li>
 
<p><strong>Suggested Compensation.</strong> The PLC must provide Conservancy&rsquo;s
 
Executive Director (or designee) with a suggested compensation (converted
 
into an hourly wage) for the technical service contractor to be retained to
 
fulfill the funded contract.</p>
 
</li>
 
<li>
 
<p><strong>Independent Assessment of Credentials.</strong> The PLC (or an unaffiliated
 
PLC Person) must provide Conservancy&rsquo;s Executive Director (or designee)
 
with a written assessment as to why the PLC Person is uniquely qualified
 
to fulfill the funded contract.</p>
 
</li>
 
<li>
 
<p><strong>Conservancy Retains Right to Request Competitive Bids.</strong> PLCs
 
acknowledge that Conservancy retains the right to ask for bids from
 
technical service contractors in addition to PLC Person to fulfill a given contract.
 
Should that instance arise, Conservancy&rsquo;s Executive Director (or designee)
 
will consult with the PLC to select the candidate best suited to fulfill
 
the contract within the budget allotted.</p>
 
</li>
 
<li>
 
<p><strong>Conservancy holds Sole Authority to Negotiate and Execute Contracts.</strong>
 
PLCs acknowledge that Conservancy holds sole authority
 
to negotiate and execute contracts on behalf of Member Projects. In
 
turn, Conservancy pledges to negotiate all contracts zealously, putting
 
the best interests of the affected Member Project first. To avoid
 
any conflicts, PLCs must not engage in any pre-negotiation with prospective
 
technical service contractors &ndash; including PLC Persons &ndash; beyond collecting the terms
 
of the technical service contractor(s)&rsquo; bid.</p>
 
</li>
 
</ul>
 
<h2 id="project-community-members-participating-corporations-and-volunteers">Project Community Members: Participating Corporations and Volunteers</h2>
 
<p>The work accomplished by Conservancy and its Member Projects would
 
not be possible without the generous donation of time, funds, and
 
support Project Community Members &ndash; including participating corporations,
 
sponsors, and volunteers alike. Community members are not traditionally
 
considered to be &ldquo;interested persons,&rdquo; and all decision-making
 
authority rests with the PLCs and/or Conservancy.</p>
 
<ul>
 
<li><strong>Community Members Cannot Direct Funds.</strong> Community Members
 
are free to offer suggestions and engage in open dialogue with PLCs and/or
 
key developers and architects regarding a Project&rsquo;s technical direction. However,
 
each PLC and Conservancy must together maintain sole and final control
 
over that Project&rsquo;s technical direction and charitable mission. Community
 
Members who make financial donations do not receive any additional
 
control over a Project&rsquo;s technical direction beyond what is available
 
to other vocal, active, and contributing community members.</li>
 
</ul>
 
<h2 id="exhibit-a-conservancy-conflict-disclosure-form">Exhibit A: Conservancy Conflict Disclosure Form</h2>
 
<p>Directors, Officers and Staff Members of Conservancy each have a duty
 
to protect Conservancy and its Member Projects from violating state
 
and federal laws &ndash; and to avoid any appearance of impropriety. Conservancy
 
Persons serve the public interest and are to have a clear understanding
 
of Conservancy&rsquo;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.</p>
 
<p>This Form is to be completed every six months and submitted to the
 
Chairperson of Conservancy&rsquo;s Board and to Conservancy&rsquo;s General Counsel.</p>
 
<p>Date: <code>__________________________</code></p>
 
<p>Next Form to be completed by (six months from now): <code>__________________</code></p>
 
<p>Name: <code>__________________________</code></p>
 
<p>Position (employee/officer/trustee): <code>_________________________________</code></p>
 
<p>I affirm the following:</p>
 
<ul>
 
<li>
 
<p>I have received a copy of the Software Freedom Conservancy Conflict
 
of Interest Policy. <code>__________________</code> (initial)</p>
 
</li>
 
<li>
 
<p>I have read and understand the policy. <code>_________</code> (initial)</p>
 
</li>
 
<li>
 
<p>I agree to comply with the policy. <code>_________</code> (initial)</p>
 
</li>
 
<li>
 
<p>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. <code>_________</code> (initial)</p>
 
</li>
 
</ul>
 
<p>Disclosures:</p>
 
<p>Please describe below any relationships, transactions, positions you
 
(or your family member) hold, or any other circumstances that you
 
believe could cause a conflict of interest as defined by the Policy
 
between your duty to Conservancy and your personal interests, financial
 
or otherwise:</p>
 
<p><code>________</code> I have no conflicts to report</p>
 
<p><code>________</code> I have the following conflicts and/or potential conflicts
 
to report:</p>
 
<pre><code>__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

	
 
__________________________________________________________________________
 
</code></pre>
 
<p>I hereby certify that the information set forth is true and complete
 
to the best of my knowledge.</p>
 
<p>Signature: <code>______________________________________</code></p>
 
<p>Date: <code>_________________</code></p>
 
<h2 id="exhibit-b-project-leadership-committee-conflict-disclosure-form">Exhibit B: Project Leadership Committee Conflict Disclosure Form</h2>
 
<p>Each volunteer, academic and/or industry professional that serves
 
on a Conservancy Member Project&rsquo;s Project Leadership Committee (PLC)
 
have a duty to act in the best interests of his or her Project when
 
making decisions about the Project&rsquo;s technical direction. Every committee
 
member must also abide by New York State and USA federal laws associated with non-profit
 
organizational governance.</p>
 
<p>Committee members must complete this form annually and submit it to
 
his or her PLC and to Conservancy&rsquo;s Executive Director.</p>
 
<p>Date: <code>_____________</code></p>
 
<p>Next Form to be completed by (one year from now): <code>___________</code></p>
 
<p>Name: <code>____________________________________</code></p>
 
<p>Position (if applicable): <code>________________________________</code></p>
 
<p>Employer (if student or self-employed, please indicate): <code>________________________________</code></p>
 
<p>I affirm the following:</p>
 
<ul>
 
<li>
 
<p>I have received a copy of the Software Freedom Conservancy Conflict
 
of Interest Policy. <code>_________</code> (initial)</p>
 
</li>
 
<li>
 
<p>I have read and understand the policy, in particular, Section 3 (relating
 
to PLCs). <code>_________</code> (initial)</p>
 
</li>
 
<li>
 
<p>I agree to comply with the policy. <code>_________</code> (initial)</p>
 
</li>
 
<li>
 
<p>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. <code>_________</code> (initial)</p>
 
</li>
 
</ul>
 
<p>Disclosures:</p>
 
<p>Please describe below any relationships, transactions, positions you
 
(or your family member) hold, or any other circumstances that you
 
believe could cause a conflict of interest as defined by the Policy
 
between your duty to your Project and your personal interests, financial
 
or otherwise:</p>
 
<p><code>________</code> I have no conflicts to report</p>
 
<p><code>________</code> I have the following conflicts and/or potential conflicts
 
to report:</p>
 
<pre><code>__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

	
 
__________________________________________________________________________
 

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

	
 
{% endblock %}
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