The purpose of this policy is to maintain the integrity of the Prevent Cancer Foundation and its decision making process. The policy requires that directors, officers, employees and committee members — referred to as stakeholders — avoid conflicts between their personal interests and the interests of the Foundation when entering into or contemplating a transaction or partnership that may benefit the private interests of any of these stakeholders.
This policy requires that stakeholders maintain personal independence with respect to their investments and refrain from making personal financial investments that benefit from information gleaned in the course of their involvement with the Foundation.
The conduct of personal business between any stakeholder and the Foundation as described below must be disclosed, and have approval from, the Foundation’s President and its Board of Directors. Such transactions shall be reviewed annually, to ensure they are in the interests of the Foundation and do not create an impermissible conflict of interest.
Stakeholder has, directly or indirectly, through business, investment or family interests:
Compensation includes direct and indirect remuneration as well as gifts or favors that are substantial in nature. The existence of a financial interest does not necessarily mean that the associated person has a conflict of interest.
Procedures for Disclosure
In the event of actual or possible conflicts of interest, the stakeholder must disclose the existence and nature of his or her financial interest and all material facts to the Foundation’s President and Board of Directors.
Upon disclosure of the financial interest and supporting material facts, the stakeholder, or Foundation President on his or her behalf, may make a presentation at the board of directors. The stakeholder must excuse herself/himself from the meeting to allow the directors to discuss and vote upon the matter under consideration.
A majority vote of the board will determine whether the transaction or arrangement that gives rise to the potential real or perceived conflict of interest is in the Foundation’s best interest and for its own benefit and whether the transaction is fair and reasonable to the Foundation. Based upon this determination, the board shall take appropriate disciplinary and/or corrective action.
If the Foundation President and/or board member has reasonable cause to believe that a stakeholder has failed to disclose actual or possible conflicts of interest, it shall inform the stakeholder of the basis for such belief and afford him or her an opportunity to explain the alleged failure to disclose. If after hearing the response of the stakeholder and investigating as may be warranted under the circumstances, the Foundation President and/or board member determines the stakeholder has in fact failed to disclose an actual or possible conflict of interest, it shall take disciplinary and/or corrective action.
Disclosure of a possible conflict of interest, and its determination and action, will be recorded in the Minutes of the Board meeting.
All stakeholders shall annually sign, and submit to the Foundation, a statement which affirms that such person: