PURPOSE
This Policy is designed to help Talisman Therapeutic Riding, Inc. (Talisman) Board of Directors and employees appropriately fulfill their legal and fiduciary responsibilities, and identify situations that present potential conflicts of interest. Talisman requires its Board members and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. While in the service of Talisman, individuals are responsible for acting in furtherance of the interests of the organization, as opposed to in furtherance of personal interests or the interests of a family member, a third party, or another organization.

A conflict of interest exists when a member of the Board of Directors or employee has a personal interest that conflicts with the interests of the organization, such that he/she may be influenced by this personal interest when deciding for the organization.  This Policy is intended to supplement but not replace any state and federal laws governing conflicts of interest applicable to nonprofit organizations.

GENERAL RULES
A conflict of interest exists where the interests or concerns of a Board member or employee are seen as competing with the interests or concerns of Talisman. Most common are situations where Talisman’s representative has a financial interest in the actions of the organization. Conflicts are, however, not limited to situations involving direct financial interests. A conflict may also exist where an insider obtains a benefit or advantage that s/he would not have obtained absent her/his relationship with the organization.

Duality of interest includes scenarios where a member of the Board of Directors or other insider has multiple interests that may make it more difficult for that individual to fulfill his or her fiduciary duty of loyalty to the organization. This conflict includes the duality of roles that many experience as a result of working with multiple organizations in their community. The fact that a conflict or duality of interest exists does not necessarily mean that the organization should not proceed with a specific action or transaction. In most instances, there is nothing unlawful about an organization transacting business with an insider. Rather, what is important in these circumstances is assuring that such transactions are scrutinized to determine whether the action or transaction is in the best interest of the organization.

DISCLOSURE
Board of Directors and employees have a variety of business, professional and personal interests, and affiliations that could affect, or be viewed as affecting, their objectivity in a decision-making process on behalf of Talisman. Appropriate disclosure promptly may mitigate a potential conflict.

A disclosure statement will be signed at the time the Board member or employee first becomes associated or involved with the organization, and annually thereafter. The same Talisman representatives subject to this Policy are under a continuing obligation to report any actual or potential conflicts as soon as they are reasonably known.

Receipt and review of the disclosure statements and actions necessary when an actual or potential conflict has been identified. If a formal review and approval of a specific Talisman action or transaction are needed, the following levels of responsibility will engage:

• Board of Directors – the Chair and Executive Committee should have access to the information disclosed by all Board members.
• Executive Director – the Chair should have access to the information disclosed by the Executive Director.
• Employees – the Executive Director should have access to the information disclosed by employees.

NEPOTISM and OTHER FAMILY RELATIONSHIPS
An applicant who is closely related to an employee is not normally eligible for employment in a position that would result in one family member directly reporting to or reviewing the performance of another. Exceptions require the advance approval of the Board of Directors.

“Closely related” is generally interpreted to mean spouse, domestic partner, parents, children, siblings, grandparents, in-laws, relatives through marriage, or members of the same household.

Employees in a supervisory relationship who become related while working at Talisman must end the supervisory relationship by resigning or transferring to an open position in another department unless approved by the Board of Directors.

OUTSIDE BUSINESS INTERESTS
Outside business interests or outside employment is permissible so long as it does not interfere with Talisman job performance, including any required overtime, or otherwise, create a conflict of interest or an appearance of a conflict of interest. Improper outside activities include but are not limited to: working for a competing organization or business; using Talisman’s time, facilities, or equipment to engage in another business or occupation; and engaging in an outside activity that results in you losing time from work, presents the appearance of a conflict or distracts you from performing satisfactorily.

GIFTS TO BOARD MEMBERS and STAFF
Accepting gifts from organizations that do business, or seek to do business, with Talisman is different from accepting gifts-in-kind that are donated to the organization and offering the donor a charitable tax deduction. These gifts are offered to members of the Board of Directors or employees as a thank you, birthday, holiday recognition, or another occasion from vendors or others with who Talisman does business (or seeks to do business). Accepting such gifts from the vendors can create the appearance of garnering favor to influence future decisions on business selection or creating personal benefit for the individual accepting the gifts.

Gifts ranging from $100 and below are considered de minimis, or of little value that it does not create undue influence. However, notification to the Executive Director should be made by all employees, even if the gift is de minimis. Board members should report such gifts to the Chair for awareness.

If a gift exceeding the de minimis threshold (over $100) is received, it will be immediately surrendered to the Executive Director. The Chair and Executive Committee will make a final determination regarding a conflict of interest or perceived conflict or duality of interest regarding the gift.

CONFIDENTIALITY
Care by all concerned Talisman parties will be exercised not to disclose confidential information acquired in connection with a conflict-of-interest status. Furthermore, Talisman Board of Directors and employees shall not disclose or use information relating to the business of Talisman for personal profit or business advantage.

REVIEW OF POLICY
Each new Board member, officer, and employee shall be required to review a copy of this Policy and to acknowledge in writing that he/she has done so and agrees to abide by this policy.

Each Board member, officer and employee shall annually complete a disclosure form identifying any relationships, positions, or circumstances in which he/she believes could contribute to a conflict of interest arising.