CONFLICT OF INTEREST POLICY

Purpose Statement:

The Board of Directors and staff of the Space Coast Health Foundation, Inc. (the “Foundation”) aspire to the highest level of ethical conduct in our work. The Foundation also values the knowledge gained from such individuals’ involvement with other organizations. Inevitably, from time to time, such affiliations may create or appear to create conflicts with the individual’s duty to the Foundation. To ensure that the Foundation’s decisions are free of any conflicts or other inappropriate influences, the Board of Directors has adopted the following policy concerning conflicts of interest and gifts.

In carrying out this policy, the Foundation relies on the good judgment and integrity of its Board of Directors and staff. The Foundation encourages a culture of transparency in which such individuals fully and promptly disclose all affiliations, interests and gifts of which they are aware that might present a conflict relating to a potential transaction or might otherwise affect their objectivity. The Foundation asks the Board of Directors and staff to bring to the attention of their colleagues, and staff members to their supervisors’ attention, all personal and professional interests or affiliations that might conflict with their duty to the Foundation. In situations where conflicts are uncertain, the Foundation encourages individuals to err on the side of disclosure.

POLICY

This policy applies to “Covered Persons,” defined as any member of the Board of Directors or staff member that has authority to act on behalf of the Foundation. Upon commencement of affiliation or employment and annually thereafter, all Covered Persons must complete a conflict of interest disclosure statement. Covered Persons are also required to update the conflict of interest disclosure statement whenever there has been a change in the Covered Persons affiliations. Covered Person’s must disclose all of their affiliations, as requested by the form, even if there is no current conflict of interest.

CONFLICTS OF INTEREST

1. Application

Generally, a conflict of interest may occur if an interest or activity influences or appears to influence the ability of a Covered Person to exercise objectivity or impairs the Covered Person’s ability to perform his or her responsibilities in the best interests of the Foundation. A Covered Person is considered to have a potential conflict of interest when:

1. The individual or any related party may receive a financial or other benefit as a result of the individual’s position at the Foundation;
2. The individual has the opportunity to influence the Foundation’s granting, business, administrative or other material decisions in a manner that leads to personal gain or advantage; or
3. The individual has an existing or potential financial or other interest which impairs or might appear to impair the individual’s independence in the discharge of their responsibilities to the Foundation.

B.      Specific Relationships that May Create Conflicts of Interest

A variety of situations, affiliations and relationships may create potential conflicts of interest. Financial or other relationships (i.e., board member or other management positions) by a Covered Person or a related party with a prospective or actual grantee, contractor, vendor or supplier could potentially create the appearance of impropriety or interfere with an individual’s discharge of the individual’s responsibilities on behalf of and in the best interests of the Foundation and should be disclosed on the Covered Person’s annual conflict of interest disclosure statement. When deciding what kind of relationships should be disclosed, consider the situation from the perspective of an outsider and whether the relationship is of such a nature that it could raise an allegation of an apparent or actual conflict of interest, and then err on the side of transparency, as disclosure helps to alleviate or avoid future misunderstandings.

The following activities illustrate types of potential or actual conflicts of interest that should be avoided and disclosed, as applicable, in accordance with this Policy. The list is not all inclusive and is intended to provide guidance.

• Self-benefit: Using your position or relationship within the Foundation to promote your own interests or those of a related party, including using confidential or privileged information of the Foundation for personal benefit or gain or for the personal gain or benefit of a related party.
• Influence peddling: Soliciting benefits for yourself or a related party from outside organizations in exchange for using your influence to advance the interests of that organization within the Foundation.
• Other business relationships and dealings: Approving grants or contracts with organizations in which an individual or a related party have a significant financial or other interest or relationship, particularly if the individuals is in a position to influence major decisions, is responsible for review, negotiation and approval of the grants or contracts or otherwise direct the Foundation’s business dealings with that business or entity.
• Property transactions: Directly or indirectly leasing, renting, trading, or selling real or personal property to or from the Foundation.
• Use of the foundation property for personal advantage: Using or taking Foundation resources, including facilities, equipment, personnel and supplies, for private use or other unauthorized non-Foundation activities.
• Recording or reporting false information: Misrepresenting, withholding, or falsifying relevant information required to be reported to external parties or used internally for decision-making purposes, in order to derive personal benefits.