This Policy is intended to define Conflict of Interest, describe instances where it may occur and outline internal processes to deal with real or potential conflict of interest.
This Policy will assist the Board of Director members, other volunteers, and employees of the Colorectal Cancer Resource & Action Network (herein “CCRAN”) to identify and avoid conflicts of interest and to allow the same individuals to deal with conflicts of interest as they arise. This Policy is created to ensure the highest standard of public trust and integrity in the work of CCRAN.
This Policy applies to all CCRAN Board of Directors, other volunteers, and all employees.
iii) Individuals who discover they are in a position of conflict of interest must take steps to disclose and restrain their participation in the conflict of interest.
i) It is the responsibility of:
- the Chair of the Board to ensure that Board Members understand and comply with this Policy.
- the CEO to ensure that employees and other volunteers understand and comply with the Policy.
ii) Where any employee, Board Member, or other volunteer feels that they may be in a conflict of interest, such individual shall immediately give notice of the potential conflict to the CEO or, if the CEO is involved, to the Chair of the Board. It is in the sole discretion of the CEO or the Chair of the Board to determine whether an exemption to this Policy shall be granted. Should such a determination be made, a report shall be tabled at the next meeting of the Board of Trustees outlining the circumstances of the situation and the reasons for the granting of the exemption. To protect the interest of those individuals giving notice to the CEO or Chair of the Board, confidentiality shall be maintained throughout the process to the extent practical and appropriate under the circumstances.
iii) If it is believed that a Board Member has not been in compliance with this Policy, an investigation will be conducted under the auspices of the Chair of the Board or the Governance and Human Resources Committee.
iv) If it is believed that an employee or other volunteer has not been in compliance with this Policy, the President, the Chief Operating Officer, or CEO may conduct an investigation. In the event of a disagreement, the Chief Financial & Operating Officer or the CEO will determine the final resolution. If the matter involves the Chief Financial & Operating Officer, it will be escalated directly by the concerned party to the CEO. If the matter involves the CEO, it will be referred to the Chair of the Board of Trustees for review.
v) The Chief Operating Officer will establish the prevailing nominal amount that CCRAN considers to be acceptable for personal gifts from sponsors, donors, volunteers, or suppliers. Currently, any gift in excess of $25.00 is not permitted.
vi) Any breach of this Policy will be considered a serious matter and dealt with immediately. Any individual knowingly violating the Conflict of Interest Policy may be subject to disciplinary action, up to and including termination.