Conflict of Interest — Employee Policy
The reputation and credibility of the Foundation rests on its ability to make fair, objective and impartial decisions in accordance with carefully defined criteria. Consequently, it is essential to avoid situations where a conflict of interest may influence, or appear to influence, that decisionmaking process. Trustee and employee behavior as relates to conflicts of interest are governed by Foundation policy. A copy of the Charles Stewart Mott Foundation Policy on Conflict of Interest can be found on this Web site.
There are two types of conflict of interest situations:
- Where a Trustee or staff member (or a relative, partner, etc.) has a financial interest, or appears to have a financial interest, in a decision.
- Where a Trustee or staff member has an affiliation with a grant applicant or other conflict of loyalties that may lead to or suggest influence in the Foundation's decision, but has no personal financial interest.
The Foundation recognizes that its Trustees and staff members have broad interests and participate in many community, charitable, and business activities. The broader the individual's experience, the more valuable is the Trustee or staff member to the Foundation.
From time to time, however, a Trustee or staff member may serve as an officer, staff member, director, trustee, or consultant to an organization under consideration for Foundation support. Situations may also arise where a Trustee's or staff member's business or personal interests may be affected by a Foundation grant decision.
In all such cases, whether involved in grantmaking or other decisions, the potential for conflict of interest should be recognized and disclosed, and appropriate steps taken to prevent influence or favoritism by such Trustee or staff member in the Foundation's grant decision. To that end, Trustees and staff members are requested annually to complete a conflict of interest disclosure statement. Even this is not enough; the Foundation and its staff should avoid any situation that might appear to have involved such influence or favoritism.
It is important to note that while these guidelines most often are applied to the grantmaking process, they apply equally to all investment and business decisions and related matters.
Two potential conflict of interest situations that may occur more frequently relate to outside employment and the receipt of gifts.
Outside Part-time Employment
As knowledgeable professionals within their respective fields, Foundation staff is sometimes requested by outside organizations to consult and/or perform contractual employment services. Often these opportunities arise within the Foundation's field of operation, creating a conflict of interest situation.
Foundation staff must use discretion in all of their dealings with outside organizations, and, in particular, with grantees, former grantees, potential grantees, and other grantmaking entities, to avoid conflicts of interest. Therefore, outside consulting services and/or other arrangements, contractual or employment, to perform services for grantees, former grantees, potential grantees and other grantmaking entities, is prohibited.
Finally, before accepting any outside consulting, contractual, or employment relationships with outside organizations, they must be discussed with your department head and authorized in writing by the President.
Gifts and Honorariums
Officers and employees are occasionally requested to speak before groups on behalf of the Foundation. As a representative, it is generally inappropriate for officers or employees to accept an honorarium, gift or similar means of payment. Further, as an employee, you and members of your immediate family should decline gifts of material value (anything in excess of $50) from grantees or potential grantees during the holidays or at any other time of year. This also applies to gifts from contractors, consultants, suppliers, etc.