Conflict Of Interest And Whistleblower Policy
Conflict of Interest
Work activities that appear to create a conflict between the interests of the organization and an employee are generally not acceptable. The American Humanist Association recognizes the right of employees to engage in activities outside of their employment that is of a private nature and unrelated to the American Humanist Association’s work. However, the employee must disclose any possible conflicts so that the organization may assess and prevent potential conflicts of interest from arising. A potential or actual conflict of interest occurs whenever an employee is in a position to influence a decision that may result in personal gain for the employee or an immediate family member (i.e., spouse or significant other, children, parents, siblings) as a result of the organization’s work. Although it is not possible to specify every action that might create a conflict of interest, this policy sets forth the ones that most frequently present problems. If an employee has any question whether an action or proposed course of conduct would create a conflict of interest, she or he should immediately contact the Executive Director to obtain advice on the issue. The purpose of this policy is to protect employees from any conflict of interest that might arise.
Violation of this policy may result in discipline, up to and including termination of employment.
Employees are required to obtain approval from their supervisor before participating in outside work activities. Approval will be granted unless the activity conflicts with the organization’s interest. In general, outside work activities are not allowed when they:
- Prevent the employee from fully performing work for which she or he is employed at the American Humanist Association, including overtime assignments;
- Involve for profit organizations that are working with or seeking to work with the American Humanist Association, including actual or potential vendors; or
- Violate provisions of law or the American Humanist Association’s policies or rules.
From time to time, the American Humanist Association full-time employees may be required to work beyond their normally scheduled hours. Such employees are expected to perform this work when requested. In cases of conflict with any outside activity, the employee’s obligations to the organization must be given priority. Employees are hired with the understanding that the American Humanist Association is their primary employer and that other employment or commercial involvement that is in conflict with the organizational interests of the American Humanist Association is strictly prohibited.
In order to retain its tax-exempt status, the American Humanist Association is prohibited from participation, intervention and/or involvement, either direct or indirect, in support of, or in opposition to any candidate for elective office or to any political party. Accordingly, all employees are expected to refrain from engaging in political activities on American Humanist Association property or on American Humanist Association business in order to avoid allegations that the private actions of its employees are in reality the actions of the American Humanist Association.
Whenever a staff member chooses to hold a position in any outside organization based on her or his expertise and her or his affiliation with the American Humanist Association, such representation shall be approved by the Executive Director. Such representation may be required to cease upon her or his resignation or termination of employment from the American Humanist Association.
Acceptance of Gifts
No employee may solicit or accept personal gifts of significant value (in excess of $100), lavish entertainment or other benefits from potential and actual donors or suppliers. Honoraria and fees received by the American Humanist Association staff as a spokesperson for the American Humanist Association are considered on a case-by-case basis, but generally will be paid as income for the American Humanist Association, not the individual. Special care must be taken to avoid even the impression of a conflict of interest. An employee may entertain potential or actual donors if such entertainment is consistent with accepted business practices, does not violate any law or generally accepted ethical standard, and the public disclosure of the facts of such entertainment will not embarrass the organization.
Reporting Potential Conflicts
An employee must promptly disclose actual or potential conflicts of interest, in writing, to the Executive Director. The Executive Director will then determine whether approval is granted. If the Executive Director must disclose a potential conflict he or she must report to the Board President.
It is important that the American Humanist Association Board of Directors be apprised about unlawful or improper behavior including, but not limited to, any of the following conduct: theft; financial reporting that is intentionally misleading; improper or undocumented financial transactions; improper destruction of records; improper use of assets; violations of the American Humanist Association’s conflict of interest policy; and any other improper occurrence regarding cash, financial procedures, or reporting.
Each employee or board member is invited to raise issues of concern, without fear of retaliation. Employees will not be disciplined, demoted, lose their jobs, or be retaliated against for asking questions or voicing concerns about conduct of this sort. At the same time, the American Humanist Association expects all employees to take this policy seriously, and to use it when necessary and in a judicious manner.
Any employee who believes that he or she has been the subject of prohibited discrimination, harassment and/or retaliation or is aware of any conduct which may be prohibited by this policy is strongly encouraged to report immediately the facts forming the basis of that belief or knowledge to the Executive Director, the Board Vice President, or the Board President. Any employee who witnesses any conduct which may be prohibited by this policy must immediately notify the Executive Director the Board Vice President, or the Board President.
Depending on who is involved in the behavior, the Executive Director, the Board Vice President or the Board President will coordinate the investigation and the American Humanist Association will take appropriate action as it deems justifiable by the circumstances. Those responsible for the investigation will maintain the confidentiality of the allegations of the complaint and the identity of the person(s) involved, subject to the need to (a) conduct a full and impartial investigation, (b) remedy any violations of American Humanist Association policies, or (c) monitor compliance with American Humanist Association policies.