|Goodwill of Central and Northern Arizona
Goodwill Industries of Monocacy Valley
|Applies to: All Team Members
|Subject: Conflict of Interest Policy
|Adopted Date: 04/27/2023
|Expires: When revised or cancelled.
|Supersedes Policy dated: 07/15/2015
|Originator: Vidula Patki, Associate General Counsel
Cindy Woodward, VP of Human Resources
|Supporting Documents: None
Goodwill of Central and Northern Arizona (“GCNA”) is committed to ensuring that it identifies and avoids both actual and perceived conflicts of interest involving Team Members. All Team Members are expected to review, be familiar with, and adhere to, this Policy.
A separate Leadership Conflicts of Interest Policy (Doc# 172) complements this Policy, but is only applicable to members of the GCNA Leadership Team.
This Policy is subject to change at any time, with or without notice. This Policy also is subject to change in accordance with applicable local, state or federal laws. GCNA retains the discretion to make exceptions to this Policy when deemed necessary or in GCNA’s best interest.
Conflict of interest means a significant financial or personal interest that could directly and significantly interfere with the Team Member’s ability to make appropriate business decisions on behalf of GCNA.
Financial Interest means anything of monetary value, whether or not the value is readily ascertainable.
A Significant Financial Interest exists if the value of any remuneration received from any entity or person in the previous twelve (12) months, when aggregated, exceeds $5,000.00, or when any Team Member (or the Team Member’s spouse or dependent) holds any equity interest in an entity or enterprise, or has intellectual property rights and interests that generate income. A Significant Financial Interest does not include the following types of financial interests:
- salary or other remuneration paid by GCNA to a Team Member;
- income from investment vehicles, such as mutual funds and retirement accounts, as long as the Team Member does not directly control the investment decisions made in these vehicles;
- income from seminars, lectures, or teaching engagements sponsored by a Federal, state, or local government agency, an Institution of higher education as defined in 20 U.S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education; or
- income from service on advisory committees or review panels for a Federal, state, or local government agency, an Institution of higher education as defined at 20 S.C. 1001(a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
Team Members must: (1) first avoid any conflict of interest, and (2) if such avoidance is not possible, affirmatively disclose any Significant Financial Interest that arises within thirty (30) days. Team Members must also disclose the occurrence of any travel that is reimbursed or sponsored by an entity other than GCNA and the purpose of such travel. This disclosure requirement does not apply, however, to travel that is reimbursed or sponsored by a Federal, state, or local government agency; an Institution of higher education as defined in 20. U.S.C. 1001(a); an academic teaching hospital; a medical center; or a research institute that is affiliated with an Institution of higher education.
All Significant Financial Conflicts of Interest must be disclosed to Cindy Woodward (VP, Human Relations) and Mona Stone (EVP, General Counsel, Chief Compliance Officer, & Corp. Secretary), both of whom shall be GCNA’s institutional officials responsible for reviewing all conflicts of interest. Team Members involved in projects funded by Federal or state dollars – or in any leadership position – must be particularly mindful of disclosing conflicts of interest. Both institutional officials shall collectively determine how to manage a disclosed conflict of interest, and whether the disclosed conflict of interest warrants public disclosure or disclosure to an affiliate or partner, removal from certain teams and responsibilities, or other action. Notably, depending on the conflict of interest and a Team Member’s responsibilities, GCNA may demand divestiture from the disclosed conflict of interest or terminate the Team Member.
If a Team Member discloses a Significant Financial Interest, the institutional officials shall maintain paperwork documenting the conflict (including value and entity or individual with whom the conflict exists), when it was disclosed, the Team Member’s responsibilities, whether the Team Member is involved in projects funded by Federal or state dollars, and management plan. Thereafter, the Team Member must update the institutional officials regarding the conflict at least annually, or whenever there is a change with the disclosed conflict of interest. All records related to a disclosed conflict of interest shall be maintained in the Team Member’s personnel file for the duration of the Team Member’s employ with GCNA and for three (3) years thereafter.
If in doubt about a particular situation, Team Members should discuss the situation with the institutional officials responsible for evaluating such disclosed conflicts.
This Policy shall be publicly available on GCNA’s website.
Team Members who violate this Policy may be subject to corrective action, up to and including termination.
Team Members with questions or concerns regarding this Policy should speak with their leader or HR Business Partner.