This Conflict of Interest Policy is designed to assist officers and employees of WORKS AND FAITH MISSION, WFM to identify situations that present potential conflicts of interest and to provide WFM with a procedure which, if observed , will process a transaction to be a valid but binding transaction. This policy applies when a member of the management team, an officer or an employee has or may have a conflict of interest for a given transaction. In the event of any inconsistency between the requirements and procedures prescribed by this policy and those of national rules and regulations, the law shall prevail.
For the purposes of this policy, the following circumstances are deemed to create conflicts of interest: An agreement or transaction between WFM and the Responsible Person or a family member. A transaction agreement between WFM and an entity in which the responsible person or family member has a material financial interest in the matter or that person is a manager, officer, agent, partner, employee representative, a director or other senior person; A Responsible Person who competes with WFM in the provision of services or in any other agreement or transaction with a third party; A person responsible for WFM accepting gifts or other favors from any individual entity that does or seeks business with, or is a competitor of, WFM; or has received, is receiving or is seeking to receive a loan or grant or obtain financial commitments from WFM; A responsible WFM person accepting gifts or other favors from a charity.
A “conflict of interest” is any circumstance described in Part 1 of this policy.
A “responsible person” is any person serving as an officer, employee or member of senior
management of WFM;
A "family member" is a spouse, parent, child or spouse of a child, sibling or spouse of a
sibling of a caregiver.
A "significant financial interest" in an entity is a financial interest of any kind that,
having regard to all the circumstances, is sufficiently significant to affect or could
reasonably affect a judgment of the responsible person or family member with respect to
the transactions in which the entity is a part. This includes all forms of compensation;
An "agreement or transaction" is any agreement or relationship involving the sale or
purchase of goods, services or rights of any kind; the making or obtaining of a loan or
grant, or the establishment of any other type of pecuniary relationship by WFM. The
granting of a donation to WFM does not constitute an agreement or transaction within the
meaning of this policy.
Each Responsible Person undertakes not to disclose confidential information required in connection with this status or information the disclosure of which could harm the interests of WFM. In addition, a responsible person must not disclose or use information relating to WFM's work for the profit or personal advantage of the responsible person or a member of the responsible person's family or private company.
Each new responsible person shall receive a copy of the policy and acknowledge it in signed writing.
Each responsible person must annually complete a disclosure form identifying any relationship, position or circumstances in which the responsible person is involved or that he or she believes could contribute to the occurrence of a conflict of interest. Such relationships, positions or circumstances may include service as a senior executive (manager) or consultant to a not-for-profit organization, or ownership of a business that may provide goods or services to WFM.
Each responsible person must also inform the WFM executive or supervisory committee of any potential conflict of interest that may arise during the year between the submission of the annual declaration forms. All information regarding the business interests of a responsible person or family member should be treated as confidential and is generally made available only to the Chairman of the Executive or Executive Supervisory Committee of WFM or his legal delegate. , and any other individuals appointed to address conflicts of interest, except where further disclosure is necessary in connection with the implementation of this policy.
The completed form of this policy will be reviewed annually by each member of the Executive or Executive/Oversight Committee. Any changes to the policy must be communicated immediately to all responsible persons.
