RWSC Conflict of Interest Policy
Purpose
The purpose of the RWSC Conflict of Interest Policy is to provide recommended definitions and processes for disclosure and decision-making around potential or realized conflicts of interest while also maximizing participation in all aspects of RWSC activities.
Definitions and Application of Policy
Individuals serving on the RWSC Steering Committee, Sector Caucuses, or Subcommittees have a “conflict of interest” if they receive of or have the potential to receive financial benefit (personal or via direct relative) from agreements developed by RWSC.
This policy shall apply to all members of the organization, as well as to all staff employees, contractors, and individuals serving on the Steering Committee, Sector Caucuses, and Subcommittees. Confirmation of individuals’ agreement to the Policy will be requested verbally upon appointment to the Steering Committee, Sector Caucuses, and Subcommittees. The terms and conditions of this Policy will be reviewed and made available to all participants prior to the discussion and consideration of issues or decisions for which conflicts may be present (e.g., funding decisions).
Notification and Disclosure
Whenever any individual has a potential or realized conflict of interest, they shall promptly call such conflict to the attention of Staff and/or the Steering Committee. This can be accomplished via written electronic or verbal communication with Staff, with the understanding that the communication will be shared with the Steering Committee.
After identifying the issue, matter, or transaction with respect to which a conflict exists, an individual with a conflict shall withdraw from any further involvement in that issue, matter, or transaction unless a majority of the disinterested directors shall determine that the conflict is:
Immaterial or not adverse to the interests of the organization; or
The benefits of allowing the person with the conflict to participate in the discussion or consideration, but not the final decision, outweigh the dangers; in which case the person may participate in the discussion, study or consideration of the issue, matter or transaction, but not the final discussion or decision.
An individual who is uncertain as to whether they may have a conflict should ask the Director for an opinion. The Director shall issue a written opinion which shall be presumed to be correct and may be relied upon unless challenged by a Steering Committee member, in which case the final decision as to whether a conflict exists shall be made by the Steering Committee. The Director shall advise the Steering Committee of every opinion issued. Opinions shall, to the extent possible, avoid the disclosure of personal information while, at the same time, disclosing the basis for the opinion. Copies of all opinions shall be retained by the organization and made available to the Steering Committee upon request to permit and encourage consistency.
The minutes of the meeting at which the disclosure of any conflict is made shall reflect that the disclosure was made and whether the person with the conflict withdrew, after making full disclosure of the matter in question and the conflict, and was not present for the final discussion of the matter and any vote thereon.
Contractually Related Conflicts of Interest
An interested individual seeking a contract from the organization cannot participate in a vote on assigning that contract, nor in any discussion on the specific contract preceding such a vote. They will be shown as abstaining due to a conflict of interest in the minutes of such a vote. The interested individual can participate in any general grant policy discussion or deliberations on whether a grant should be pursued.