This Conflict of Interest policy applies to all persons holding positions of responsibility and trust on behalf of Community Foundation of Western Massachusetts (“the Foundation”) including, but not limited to, Foundation Trustees, members of the Distribution Committee and other volunteer committees or workgroups, and employees of the Foundation (hereinafter “Members”). Members may occasionally have conflicts of interest or situations where appearance of a conflict of interest could be detrimental to the Foundation and the interests it serves.

It is the policy of the Foundation that no Member shall derive any personal profit or gain, directly or indirectly, by reason of their service to the Foundation, with the exception of compensation and benefits to employees of the Foundation.

To help ensure the Foundation’s commitment to integrity, Members must in writing disclose to the Foundation any affiliation of the Member or the Member’s immediate family with any entity with which the Foundation has a transaction or arrangement. Affiliation includes, but is not limited to, an ownership interest, service as a board member, manager, officer, employee or consultant, or any compensation or other financial arrangement. The Members shall provide such disclosures at least annually, but Members are expected to disclose such affiliations as they arise. In addition, when a grant, action or policy is under consideration, if a Member’s conflict of interest with respect thereto has not been disclosed as provided above, the Member must in writing disclose to the Foundation any position held or business activity engaged in by such Member that may result in a possible conflict of interest or bias regarding such grant, action or policy. The disclosures will be maintained by the VP of Finance & Operations or equivalent.

A Member who may have a conflict of interest or such a bias respect to a matter may not be present during any portion of a meeting during which such matter is considered unless the chair of the body considering such matter requests the Member’s presence to give factual information. A Member may not vote on or attempt to influence the outcome of such matter. The disclosure and abstention should be formally noted in the meeting minutes.

If a Member may have a material financial conflict of interest, the preceding paragraph shall apply and the Foundation Trustees shall determine whether such conflict of interest exists. If they determine that it does, they shall determine if the Foundation could expect to obtain with reasonable efforts a more advantageous transaction or arrangement not involving a conflict of interest. If they determine that the Foundation cannot expect a more advantageous transaction or arrangement, they shall determine if the proposed transaction or arrangement is fair and reasonable and benefits and is in the best interests of the Foundation. The minutes of the Foundation Trustees shall contain a record of all such deliberations.

The chair of the Foundation Trustees will be responsible for the application and interpretation of this policy as it relates to the Foundation Trustees, the Foundation President & CEO or any financial conflict of interest. In all other instances, the President & CEO shall be responsible for application and interpretation of these policies.

In order to ensure that these policies are followed, the VP of Finance & Operations or equivalent officer of the Foundation shall provide the chair of the Foundation Trustees and of each committee and work group of the Foundation a disclosure report outlining potential conflicts pertaining to the body chaired by such chair.