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Conflict of Interest Policy

The American Public Health Association requires its directors, officers, employees, members and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The Association depends on the active involvement and voluntary leadership of its members to accomplish its mission and to maintain its credibility as a valued resource.  All shall scrupulously avoid any conflict between their own respective personal, professional, or business interests and the interests of the Association, in any and all actions taken by them in their respective capacities on behalf of the Association.  When in a leadership position, APHA requires that leaders conduct themselves with honesty and integrity.

The purpose of this Policy (PDF) is to foster public confidence and to protect the Association’s interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of a director, officer or other person in a position of authority within the Association.  The Association strives to avoid conflicts of interest to ensure that it preserves the highest standards of integrity and ethical principles.  When unable to avoid an actual conflict, the conflict will be disclosed and managed through a systematic procedure of:

  1. Disclosing conflict to the proper persons
  2. Refraining from participating in the decision-making process (recusal)
  3. Documenting the disclosure, recusal, and voting process and decision

The Conflict of Interest Policy fulfills the Internal Revenue Service requirement, for those organizations that are entrusted with resources devoted to charitable purposes, to have such a policy and protects the Association’s tax-exempt status.1

The Association does not exclude individuals from seeking positions of leadership based on perceived, potential, or actual conflict of interests.  The duty to loyalty requires that those individuals seeking leadership positions be transparent about potential for conflicts and act with candor, care, and disclosure (with recusal when appropriate) in dealing with situations as they arise.

Membership has an opportunity to indicate its level of ease in respect to duty of loyalty with those in leadership positions through the process of election to office. 

While all APHA members, employees, and volunteers should be aware of and abide by the policy, executive board members; governing councilors; key employees; chairs of sections, SPIGS, and forums as well as chairs of APHA-wide committees and boards  must  annually sign a Conflict of Interest acknowledgement statement.

IRS Background1:

While the Internal Revenue Service (IRS) does not prescribe a specific conflict of interest policy for nonprofit corporations, it does note in instructions for Form 1023 the importance of having a policy to protect the organization’s tax-exempt status.

 A conflict of interest policy is intended to help ensure that when actual or potential conflicts of interest arise, the organization has a process in place under which the affected individual will advise the governing body about all the relevant facts concerning the situation. A conflict of interest policy is also intended to establish procedures under which individuals who have a conflict of interest will be excused from voting on such matters.

(IRS, April 2015, http://www.irs.gov/Charities-&-Non-Profits/Form-1023:-Purpose-of-Conflict-of-Interest-Policy)

IRS Form 990 Part VI., Section A. Governing Body and Management asks if the organization has a written conflict of interest policy (12a-12c).

Did the organization have a written conflict of interest policy?  Were officers, directors, or trustees, and key employees required to disclose annually interest that could give rise to conflicts?  Did the organization regularly and consistently monitor and enforce compliance with the policy?

(IRS, 2014, Form 990, Return of Organization Exempt From Income Tax)

Related Information (all are downloadable PDFs):