Conflict of Interest Disclosure Policy

1. Purpose

The purpose of this policy is to ensure transparency and integrity by requiring personnel to disclose any actual, potential, or perceived conflicts of interest. This protects organizational impartiality, operational credibility, and public trust.

2. Scope

This policy applies to:

  • Full-time employees
  • Part-time employees
  • Contract personnel
  • Operational volunteers
  • Supervisory and executive leadership

All personnel must comply with this policy while performing duties or representing the organization.

3. Definition of Conflict of Interest

A conflict of interest occurs when an individual’s personal, financial, or professional relationships could:

  • Influence, or appear to influence, their judgment or decisions
  • Interfere with impartial execution of organizational duties
  • Create a competitive advantage or preferential treatment

Examples include, but are not limited to:

  • Relationships with law enforcement personnel, agencies, or investigative bodies
  • Financial or business ties to vendors, contractors, or service providers
  • Political affiliations or close relationships with elected officials
  • Involvement with private entities that could benefit from organizational decisions

4. Disclosure Requirements

  • All personnel must submit a written disclosure of potential conflicts:
    • Upon hiring or engagement
    • Annually thereafter
    • Whenever a new potential conflict arises
  • Disclosures must detail the nature of the relationship and any relevant interests
  • Disclosure forms must be submitted to the designated compliance officer or executive leadership

5. Review and Resolution

  • Executive leadership or the compliance officer shall review all disclosures
  • Appropriate actions may include:
    • Recusal from specific decisions or assignments
    • Reassignment of duties
    • Modification of access to sensitive information
    • Monitoring for compliance
  • Disclosures and resolutions shall be documented in personnel records

6. Non-Compliance

Failure to disclose a conflict of interest may result in:

  • Corrective action or counseling
  • Reassignment or removal from assignments
  • Suspension or termination of employment/engagement
  • Reporting to relevant authorities if legal violations occur

7. Confidentiality

  • All disclosures are treated as confidential, with access limited to authorized personnel for review and resolution purposes
  • Personnel are protected from retaliation for making disclosures in good faith

8. Policy Review

This policy shall be reviewed annually to ensure it remains effective and consistent with organizational ethics, operational standards, and applicable Massachusetts laws