Conflict of Interest Policy
This Conflict-of-Interest Policy (“Policy”) is established to ensure
that the employees of
Operation HOPE
act in the best interest of the Organization and avoid
conflicts of interest that could compromise their impartiality or
integrity. Employees owe a duty of loyalty to the Organization
and should act in its best interests at all times. They must avoid
any activity or association that could impair their independence or
judgment. This Policy outlines the guidelines and procedures
that Individuals must adhere to in identifying, disclosing,
managing, and resolving conflicts of interest.
Definition
Conflicts of interest occur when an employee has a personal or
business interest or activity that impairs or appears to impair
their ability to perform their duties and responsibilities in the
best interest of
Operation HOPE. A conflict occurs when an individual converts their
relationship with Operation
HOPE
contacts, clients, or partners for financial gain for themselves or
family members.
An actual conflict of interest need not be present to require
disclosure in accordance with this Policy. Activities that
appear to create a conflict of interest must be avoided to prevent a
negative impact on the mission and reputation of
Operation HOPE.
For purposes of defining conflicts,
Operation HOPE
categorizes them as direct and indirect.
Direct Conflict
A direct conflict occurs when the outside interest, business or
employment of an individual competes with the actual service
deliverables of
Operation HOPE
and the individual and or family member receives compensation
(direct/indirect) from the service provided.
Example: A conflict arises when you offer (refer
someone) any service that
Operation HOPE
offers (financial coaching, including but not limited to,
credit/homeownership/small business) that directly competes with
services offered by Operation
HOPE.
You violate this even if you are not directly responsible for
providing the service.
This is a direct violation of the conflict-of-interest policy.
Indirect Conflict
An indirect conflict is defined as a conflict of interest that is
not directly tied to the day-to-day business operations of
Operation HOPE. An example of an indirect conflict would be to take any
relationship established through the business practice/relationship
with Operation
HOPE and
convert it for personal/familial financial gain.
Example: A contact derived from the relationship
with
Operation HOPE
(client or partnership) has a taxi service. They are looking
for a mobile detail contact. You or someone in your immediate
family who owns a mobile detail business and you offer your services
to the client/partner.
This is an indirect violation of the conflict-of-interest policy.
Disclosure
Operation HOPE
employees are required to identify and disclose all actual and
potential conflicts and to work with the appropriate Operation
HOPE
personnel to manage conflicts.
All disclosures will be held confidential, only to be shared with
the necessary
Operation HOPE
individuals.
Employees must promptly and fully disclose any actual or potential
conflicts of interest, whenever they arise. If an employee
finds themselves questioning whether their activities or the
activity of a co-worker constitutes a violation of this policy, they
must disclose their concerns.
Disclosure Process
-
Submit your request through the COI ticketing app located on the
ADP Workforce
landing page.
-
We will acknowledge receipt of the disclosure within 48 hours.
-
Upon receiving a disclosure, we willl investigate and evaluate the
conflict of interest
to determine whether it exists, is material, or could reasonably
influence a decision
or compromise the Organization’s integrity.
-
Operation HOPE
will make a final determination regarding the disclosure and
determine options on how to cure the conflict.
Confidentiality
All disclosed conflicts of interest shall be treated as
confidential, with information shared only with those who have a
legitimate need to know.
Records
Operation HOPE
will maintain a record of all disclosed conflicts of interest,
including the nature of the conflict, the individuals involved, and
the actions taken to address the conflict.
Audits
Operation HOPE
will conduct periodic audits, investigations, and inquiries to
ensure compliance with this policy.
Annual Compliance
Operation HOPE
will require an annual attestation of compliance from all employees.
This Policy may be amended, modified, or supplemented by Operation
HOPE at any
time. The Policy shall be reviewed periodically to ensure its
eNectiveness and compliance with applicable laws and regulations.
Commitment
By adopting this Conflict-of-Interest Policy,
Operation HOPE
demonstrates its commitment to maintaining the highest standards of
ethics, integrity, and transparency in its operations. All employees
associated with Operation
HOPE are
expected to always comply with this Policy and act in the best
interest of the Organization. This is a corporate-wide Policy and
applies to all employees. The Policy supplements, but does not
supplant, state and federal laws governing conflicts-of-interest or
create any statutory rights.
Violation of this Policy may result in disciplinary action, up to
and including termination of employment, or other appropriate
actions based on the severity and circumstances of the violation.
