Conflict of Interest Policy

Purpose

The purpose of this Conflict of Interest Policy is to protect the interests of Camp Monarch, a nonprofit organization, when it is contemplating entering into a transaction or arrangement that might benefit the private interest of one of its board members or result in a possible excess benefit transaction. This policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.

Definitions

1. Interested Person: Any board member, principal officer, or member of a committee with governing board-delegated powers who has a direct or indirect financial interest, as defined below, is considered an interested person.

2. Financial Interest: A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:

   • An ownership or investment interest in any entity with which Camp Monarch has a transaction or arrangement,

   • A compensation arrangement with Camp Monarch or with any entity or individual with which Camp Monarch has a transaction or arrangement, or

   • A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which Camp Monarch is negotiating a transaction or arrangement.

Disclosure of Conflicts

Each board member is required to disclose any potential conflicts of interest on an annual basis and also promptly when any relevant conflicts arise throughout the year. Such disclosure must occur prior to any board discussions or votes related to the potential conflict.

Procedures

1. Duty to Disclose: In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest or other conflict of interest to the board or appropriate committee.

2. Determining Whether a Conflict of Interest Exists: After disclosure of the financial interest or other conflict, the board or committee will decide if a conflict of interest exists.

3. Procedures for Addressing the Conflict of Interest:

   • An interested person may make a presentation at the board or committee meeting but must abstain from voting on the transaction or arrangement that involves the conflict of interest.

   • The chair of the board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.

   • After exercising due diligence, the board or committee shall determine whether Camp Monarch can obtain a more advantageous transaction or arrangement with reasonable efforts that would not give rise to a conflict of interest.

Violations of the Conflict of Interest Policy

1. If the Board has Reasonable Cause to Believe a Member has Failed to Disclose: If the board has reasonable cause to believe that a member has failed to disclose an actual or possible conflict of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.

2. Response to Violations:

   • First Violation: The board shall issue a written warning to the member.

   • Subsequent Violations: If additional violations occur, the board may conduct an investigation and take further appropriate action, which could include a reprimand or, in extreme cases, removal from the board if warranted, by a majority vote.

Annual Statements

Each board member shall annually sign a statement that affirms such person:

• Has received a copy of this Conflict of Interest Policy,

• Has read and understands the policy,

• Agrees to comply with the policy, and

• Understands that Camp Monarch is a nonprofit organization and must engage primarily in activities that accomplish its tax-exempt purposes.

Conflict of Interest Disclosure Form

Board Member Name: ______________________________________
Date: ______________________________________________________

Please list any entities, organizations, or personal relationships that may pose a conflict of interest with Camp Monarch:

I affirm that I have read and understand the Conflict of Interest Policy and agree to comply with it.

Signature: ______________________________________
Date: ___________________________________________