Conflict of Interest Policy Once the arrows appear, you can move forward or backward through the presentation.

Why is this policy important? Charitable organizations such as Heifer serve the public interest as opposed to private interests, and are therefore frequently subject to intense scrutiny from many sources – including the general public and the IRS.

Why is this policy important? This policy will assist Heifer in avoiding impropriety and/or the appearance of impropriety, and will help Heifer protect and maintain its 501(c)(3) tax-exempt status.

Why is this policy important? The IRS publishes an excellent document entitled “Compliance Guide for 501(c)(3) Public Charities” that summarizes key compliance issues facing charitable organizations such as Heifer. You may access this document on HIP via Legal Services’ “Compliance” page.

What is the general intent of this policy? To ensure a clear process is in place that allows Heifer to fairly and efficiently address actual or potential conflicts of interest among its employees, volunteers, temporary workers, and interns.

When is the policy effective? April 1, 2010 for US-based employees, volunteers, temporary workers, and interns. June 1, 2010 for all employees, volunteers, temporary workers, and interns not based in the US.

What is a conflict of interest? An actual or potential conflict of interest will generally occur when your obligations to Heifer are at odds with your or your family’s private interests. Some situations susceptible to conflicts of interest are described beneath each applicable policy subsection* in the following slides: * Definitions for the terms “Interested Party”, “Family”, and “LSE” appear in the policy itself.

Applicable Policy Subsection: Policy Subsection 2(a)(i): Employees, volunteers, temporary workers, and interns must carry out their work in compliance with all applicable laws, rules, and regulations.

Policy Subsection 2(a)(i) examples of situations susceptible to conflicts of interest: Carrying out fundraising in a State where Heifer is not registered. Failing to withhold employment taxes as required by law. Using another party’s intellectual property without a license.

Applicable Policy Subsection: Policy Subsection 2(b)(i): Employees, volunteers, temporary workers, and interns must not allow, or attempt to influence Heifer in such a way as to allow, any part of Heifer’s assets to benefit the private interest of an Interested Party.

Policy Subsection 2(b)(i) examples of situations susceptible to conflicts of interest: Entering a contract on Heifer’s behalf that allows an entity in which you or your family member has an interest to provide goods or services to Heifer for profit. Paying unreasonable compensation to an employee. Buying Heifer property from Heifer at an unreasonably low price.

Applicable Policy Subsection: Policy Subsection 2(b)(ii): Employees, volunteers, temporary workers, and interns must not serve in a position of authority with an LSE that allows the employee, volunteer, temporary worker, or intern to influence the LSE’s decisions.

Policy Subsection 2(b)(ii) examples of situations susceptible to conflicts of interest: Serving as a board member of a legally separate entity. Serving as an officer of a legally separate entity. Serving as an employee of a legally separate entity.

Applicable Policy Subsection: Policy Subsection 2(b)(iii): Employees, volunteers, temporary workers, and interns must not give, receive, or facilitate the giving or receiving of, an unofficial item of value intended to influence or enhance the performance of an official duty.

Policy Subsection 2(b)(iii) examples of situations susceptible to conflicts of interest: Paying an unofficial fee to a government official to maintain Heifer’s 501(c)(3) status. Hiring the child of a government official to obtain fully registered status in a country. Accepting a business opportunity in exchange for livestock.

Applicable Policy Subsection: Policy Subsection 2(b)(iv): Employees, volunteers, temporary workers, and interns must not engage in activities that are in direct conflict with Heifer’s mission.

Policy Subsection 2(b)(iv) examples of situations susceptible to conflicts of interest: Serving in an active role with an entity that advocates hunger. Serving in an active role with an entity that promotes poverty. Serving in an active role with an entity that advocates pollution.

What process is followed when a suspected actual or potential conflict of interest is reported? Human Resources will investigate and submit a report, along with any related documentation, to Heifer’s Senior Leadership Team (SLT). SLT will review the information, determine whether a conflict of interest exists and, if it does, vote to authorize or reject the transaction or activity, and/or take any other action deemed necessary to address the situation.

An example from beginning to end… Employee A suspects Employee B has entered into a contract on Heifer’s behalf with a company owned by Employee B’s daughter. Employee A reports the suspected activity on Heifer’s anonymous Listen Up tool.

Human Resources, with assistance from Legal Services, reviews the contract, interviews Employee B, and learns that—while the contracted company is owned by Employee B’s daughter—Employee B was not Heifer’s signatory on the contract. An example from beginning to end…

Human Resources presents a report to SLT that includes the contract and a summary of the facts. SLT determines the contract terms are objectively fair to Heifer and requests that, in the future, contracts like the one described above be presented to SLT for objective consideration prior to Heifer entering into the contract. An example from beginning to end…

Thank you for participating in Heifer’s Conflict of Interest Policy training. To acknowledge that you read the Conflict of Interest Policy and agree to comply with it: Click on the link below, complete and submit the Brief Acknowledgement Form. Conflict of Interest Policy Acknowledgement Form Next Steps