Conflict of Interest Policy
Military Children's Six Foundation MC6) is committed to conducting operations in a manner that requires the highest ethical standards of employees, of the MC6 Foundation, and non-employees at third parties acting on behalf of the MC6 Foundation, by using the Foundation’s assets efficiently to achieve the objectives laid out in the MC6 Foundation’s charter; and to take measures to ensure decisions are not influenced by self-interest.
The purpose of this policy is to provide guidance in identifying and handling potential and actual conflicts of interest involving the MC6 Foundation.
Employees of the Foundation are expected to conduct their relationships with each other, the Foundation, MC6 entities, and outside organizations with objectivity and honesty. The basic purpose of this policy is to avoid that an employee places his or her personal interests before the interests of the MC6 Foundation and that such personal interests unduly influence professional judgments, decisions, or actions.
This policy applies to all employees of the MC6 Foundation in the USA and abroad (including entities that the MC6 Foundation controls) and third parties acting on behalf of the MC6 Foundation, regardless of the country or the jurisdiction where they are based.
All employees have a personal responsibility to live up to the standards set out in this policy, as well as a continual review of outside interests or relationships for actual, potential, or perceived conflicts of interest. Leaders have a leadership role and are responsible for preventing conflicts of interest and taking action if needed.
As part of employment with the MC6 Foundation, employees have a contractual obligation of loyalty to the MC6 Foundation.
Below are described the requirements of this policy. Employees are expected to understand when a conflict of interest may arise and must avoid conflicts of interest wherever possible. Further, Leaders must ensure conflicts of interest are appropriately addressed.
Identifying Conflicts of Interest
The MC6 Foundation defines conflicts of interest accordingly:
Actual conflicts of interest (the employee faces a real, existing conflict);
Potential conflicts of interest (the employee is in or could be in a situation that may result in a conflict);
Perceived conflicts of interest (the employee is in or could be in a situation that may appear to be a conflict, even if this is not the case).
Conflicts of interest may arise in situations that benefit friends, former business colleagues, and/or closely related persons as defined in the table below.
Generally, a conflict of interest exists if:
An individual or his/her closely related person and/or friend and/or former business colleagues may receive financial or other significant benefits as a result of the person’s position at the MC6 Foundation;
An individual has an existing or potential financial or other significant interest that impairs or might appear to impair the person’s independence in performing their MC6 Foundation responsibilities.
Common examples of conflict-of-interest situations include personal workplace relationships e.g. hiring or supervising a closely related person or promoting personal financial interests. Please also remember to respect our Gifts, Hospitality & Entertainment Policy, as excessive gifts, hospitality, and entertainment can be seen as a potential conflict of interest.
Responding to Conflicts of Interest
The MC6 Foundation respects employees’ rights and choices and does not wish to interfere with their personal lives. However, employees’ avoidance of conflicts of interest is an important part of maintaining the integrity and sustainability of our projects and builds trust and support amongst colleagues and our key stakeholders.
In order to assure impartial decision-making, the general rule is that MC6 Foundation employees are obligated to avoid conflicts of interest involving the MC6 Foundation and disclose them using the Conflict-of-Interest Declaration Form (Annex 1).
Disclosure of Conflicts of Interest
Addressing a conflict of interest is the process of identifying and implementing practices and actions to minimize the risks associated with the disclosed conflict of interest.
Employees are expected to recognize when they have, potentially have, or could be perceived as having, a conflict of interest. Employees should consult their Leader if in doubt about what circumstances might create a conflict of interest and use the Conflict-of-Interest Declaration Form of this Policy (Annex 1).
Conflicts of interest should be disclosed in due time in the MC6 Foundation’s decision-making process and the Conflict of Interest Declaration Form must be completed by the employee and the Leader.
The MC6 Foundation HR will keep the completed Conflict of Interest Declaration forms on the relevant employee file.
A breach of this policy may result in disciplinary action, which could include termination of employment and legal action. If laws have been violated, the MC6 Foundation will cooperate fully with the appropriate authorities.
Disciplinary action will be taken against any individual who is found to have authorized, condoned, participated in, or concealed actions that breach this policy and who retaliate, directly or indirectly, or encourage others to retaliate against an employee or non-employees at a third party who reports a breach.
All employees or third parties acting on our behalf have an obligation to immediately report any knowledge of a breach or suspected breach of this policy. Third parties should report through their MC6 Foundation employee contact. Anyone who withholds information concerning a breach or suspected breach may be subject to disciplinary action.
Any incident must be reported to either:
A person in a formal leadership capacity at the MC6 Foundation (your manager or manager’s manager);
The MC6 Foundation Compliance Department
If you are in doubt as to whether a breach has occurred, or if you need guidance to make a decision, you are encouraged to seek assistance from Legal Services.
The MC6 Foundation will handle all reports discreetly and will make every effort to protect, within the limits allowed by law, the identities of anyone reporting a possible breach. There will be no retaliation from the MC6 Foundation for making a report. Any employee reporting in good faith a possible breach shall not be disciplined for submitting a report provided that the employee is not involved in the breach.
The following term and definitions are used in this document: Closely related persons
Closely related persons are the employee’s family members, someone with whom the employee has an intimate relationship, and those living in the same household as the employee.