Conflict of Interest Policy
- Conflict of Interest Defined
For purposes of this policy, the following circumstances shall be deemed to create Conflicts of Interest:
- Outside Interests.
- An Agreement or Transaction between Danish Siddiqui Foundation and a Responsible Person or Family Member.
- An Agreement or Transaction between Danish Siddiqui Foundation and an entity in which a Responsible Person or Family Member has a Material Financial Interest or of which such person is a director, officer, agent, partner, associate, trustee, personal representative, receiver, guardian, custodian, conservator, or other legal representatives.
- Outside Activities.
- A Responsible Person competing with Danish Siddiqui Foundation in the rendering of services or in any other Agreement or Transaction with a third party.
- A Responsible Person’s having a Material Financial Interest in; or serving as a director, officer, employee, agent, partner, associate, trustee, personal representative, receiver, guardian, custodian, conservator, or other legal representative of, or consultant to; an entity or individual that competes with Danish Siddiqui Foundation in the provision of services or in any other Agreement or Transaction with a third party.
- Gifts, Gratuities and Entertainment. A Responsible Person accepting gifts, entertainment, or other favors from any individual or entity that:
- does or is seeking to do business with, or is a competitor of Danish Siddiqui Foundation; or
- has received, is receiving, or is seeking to receive a loan or grant, or to secure other financial commitments from Danish Siddiqui Foundation;
- is a charitable organization
- under circumstances where it might be inferred that such action was intended to influence or possibly would influence the Responsible Person in the performance of his or her duties. This does not preclude the acceptance of items of nominal or insignificant value or entertainment of nominal or insignificant value that are not related to any particular transaction or activity of Danish Siddiqui Foundation.
- Outside Interests.
- Definitions
- 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 the board of directors of Danish Siddiqui Foundation.
- A “Family Member” is a spouse, domestic partner, parent, child, or spouse of a child, brother, sister, or spouse of a brother or sister, of a Responsible Person.
- A “Material Financial Interest” in an entity is a financial interest of any kind that, in view of all the circumstances, is substantial enough that it would, or reasonably could, affect a Responsible Person’s or Family Member’s judgment with respect to transactions to which the entity is a party. This includes all forms of compensation. (The board may wish to establish an amount that it would consider to be a “material financial interest.”)
- An “Agreement or Transaction” is any agreement or relationship involving the sale or purchase of goods, services, or rights of any kind, the providing or receipt of a loan or grant, or the establishment of any other type of pecuniary relationship by Danish Siddiqui Foundation. The making of a gift to the Danish Siddiqui Foundation is not an Agreement or Transaction within the meaning of this document.
- Procedures
- Before board or committee action on an Agreement or Transaction involving a Conflict of Interest, a director or committee member having a Conflict of Interest and who is in attendance at the meeting shall disclose all facts material to the Conflict of Interest. Such disclosure shall be reflected in the minutes of the meeting.
- A director or committee member who plans not to attend a meeting at which he or she has reason to believe that the board or committee will act on a matter in which the person has a Conflict of Interest shall disclose to the chair of the meeting all facts material to the Conflict of Interest. The chair shall report the disclosure at the meeting and the disclosure shall be reflected in the minutes of the meeting.
- A person who has a Conflict of Interest shall not participate in or be permitted to hear the board’s or committee’s discussion of the matter except to disclose material facts and to respond to questions. Such person shall not attempt to exert his or her personal influence with respect to the matter, either at or outside the meeting.
- A person who has a Conflict of Interest with respect to an Agreement or Transaction that will be voted on at a meeting shall not be counted in determining the presence of a quorum for purposes of the vote. The person having a conflict of interest may not vote on the Agreement or Transaction and shall not be present in the meeting room when the vote is taken, unless the vote is by secret ballot. Such a person’s ineligibility to vote shall be reflected in the minutes of the meeting.
- Responsible Persons who are not members of the board of directors of the Danish Siddiqui Foundation, or who have a Conflict of Interest with respect to an Agreement or Transaction that is not the subject of board or committee action, shall disclose to the Chair or the Chair’s designee any Conflict of Interest that such Responsible Person has with respect to an Agreement or Transaction. Such disclosure shall be made as soon as the Conflict of Interest is known to the Responsible Person. The Responsible Person shall refrain from any action that may affect Danish Siddiqui Foundation’s participation in such Agreement or Transaction.
- In the event it is not entirely clear that a Conflict of Interest exists, the individual with the potential conflict shall disclose the circumstances to the Chair or the Chair’s designee, who shall determine whether there exists a Conflict of Interest that is subject to this policy.
- Confidentiality
Each Responsible Person shall exercise care not to disclose confidential information acquired in connection with such status or information the disclosure of which might be adverse to the interests of the Danish Siddiqui Foundation. Furthermore, a Responsible Person shall not disclose or use information relating to the business of the Danish Siddiqui Foundation for the personal profit or advantage of the Responsible Person or a Family Member or the Responsible Person’s company.