Sample Conflicts of Interest and Documentation Form



This Conflicts of Interest and Documentation Policy (“Policy”) applies to all directors and officers of ____________________ (“[Corporation/Foundation]”) and any other person who is in a position to exercise substantial influence over the decisions and affairs of the [Corporation/Foundation] (collectively, “Covered Persons”).


The purpose of this Policy is to protect the [Corporation/Foundation]’s interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of a Covered Person or might result in a possible excess benefit transaction (“Proposed Transaction”). This Policy provides procedures for identifying situations that represent potential conflicts of interest, determining whether a conflict of interest exists and if present, addressing such conflict of interest. Procedures are also provided for periodic reviews to ensure that the [Corporation/Foundation] is being operated in a manner consistent with its tax-exempt status. This Policy supplements (but cannot replace) any applicable laws governing conflicts of interest applicable to nonprofit organizations.


The terms in this Policy with initial letters capitalized have the meaning set forth in the section entitled “Definitions” or the meaning as designated in places throughout this Policy.

To