Conflict of Interest Policy

The Kringle Cause, Inc. is committed to transparent and ethical leadership. To maintain the public trust and comply with IRS regulations governing 501(c)(3) organizations, we have adopted a formal Conflict of Interest Policy.

This policy applies to all board members, officers, key employees, and any individuals involved in decision-making or financial oversight for the organization.

1. Purpose

The purpose of this policy is to ensure that personal, professional, or financial interests do not interfere with the impartiality, integrity, or mission of The Kringle Cause.

Even the appearance of a conflict can harm public confidence. This policy helps us identify and manage potential conflicts early and appropriately.

2. Definition of Conflict of Interest

A conflict of interest occurs when a person in a position of authority within The Kringle Cause could benefit personally—either directly or indirectly—from a decision they make on behalf of the organization.

Conflicts may arise when:

• The individual or a family member has a financial interest in a vendor or contractor
• The individual serves on another board or is employed by an organization with similar services or funding needs
• A decision could result in personal or professional gain beyond what is reasonable or customary

3. Disclosure Process

All current and incoming board members, officers, and key personnel must complete an Annual Conflict of Interest Disclosure Form, and again:

• Upon onboarding
• Annually thereafter
• Anytime their circumstances materially change

The completed forms are reviewed and retained by the Secretary of the Board or another designated officer.

4. Recusal & Board Oversight

If a potential conflict arises, the individual must:

• Disclose the nature of the conflict immediately
• Refrain from participating in any discussion or vote related to the matter
• Exit the room during deliberations if requested

The remaining disinterested board members will determine whether a conflict exists and how to proceed in the organization’s best interest.

5. Documentation

All disclosures, discussions, and votes related to conflicts of interest are recorded in the official meeting minutes for transparency and audit purposes.

6. Accountability

Failure to disclose a conflict or follow this policy may result in removal from a position of authority or other corrective action, depending on severity.

7. Policy Availability

This policy is provided to all board members and officers during onboarding and is published in the Board of Directors Manual (Page 14). It is also available online and upon request.

When decisions are made in the spirit of service and transparency, everyone wins—especially the children and families we serve.

‍