Conflict of Interest Policy
First State Educate (FSE) Conflict of Interest Policy (2025)
Approved September 21, 2025
Purpose
First State Educate (“FSE”) is committed to maintaining the highest standards of integrity and accountability in all aspects of its work. This Conflict of Interest Policy is intended to protect FSE’s interests when it is contemplating entering into a transaction or arrangement that might benefit the private interest of a board member, officer, employee, or volunteer. The policy also serves to ensure transparency and safeguard public trust in FSE’s mission.
Covered Persons
This policy applies to all members of the Board of Directors, officers, employees, consultants, and volunteers who are in positions to influence FSE’s decisions (“Covered Persons”).
Definition of Conflict of Interest
A conflict of interest exists when a Covered Person’s personal, professional, or financial interests may interfere—or appear to interfere—with their ability to act in the best interests of FSE. Examples include, but are not limited to:
Having a financial interest in, or receiving compensation from, an entity that does business with FSE.
Using FSE resources, influence, or information for personal gain.
Participating in decisions that could benefit a family member, business associate, or personal interest.
Duty to Disclose
Covered Persons must disclose any actual, potential, or perceived conflict of interest to the Board of Directors (or the Executive Director, in the case of staff and volunteers) as soon as the conflict becomes known.
Procedures
Disclosure
All Covered Persons will complete an annual Conflict of Interest Disclosure Form.
Any conflicts arising during the year must be disclosed promptly.
Determination
The disinterested members of the Board of Directors will review disclosures and determine whether a conflict exists and what steps are necessary to manage it.
Recusal
A Covered Person with a conflict must recuse themselves from any discussion, decision, or vote related to the matter.
Documentation
All conflict disclosures and related actions will be recorded in the meeting minutes or other official records.
Violations
Failure to disclose a conflict of interest may result in disciplinary action, up to and including removal from the Board, termination of employment, or dismissal from volunteer service.
Annual Acknowledgment
Each Covered Person must sign an annual statement affirming that they:
Have received and read this Conflict of Interest Policy,
Agree to comply with it, and
Understand that FSE is a nonprofit organization and that in order to maintain its federal tax exemption, FSE must engage primarily in activities that accomplish one or more of its tax-exempt purposes.
CONFLICT OF INTEREST DISCLOSURE FORM
Date: ____________________
Name: __________________________________________
Title/Position: ____________________________________
Please describe below any relationships, transactions, positions you hold (as owner, director, or volunteer of a for-profit or nonprofit organization) or circumstances that you believe could contribute to an actual or perceived conflict of interest between First State Educate and your personal interests—financial, dual loyalty, or otherwise. (Use additional paper if necessary):
I (or my spouse/life partner) sit on the following nonprofit board(s):
I (or members of my family as specified in the Organization’s Conflict of Interest Policy) am/are an owner, officer, director, or majority shareholder of the following for-profit business(es):
I (or members of my family as specified in the Conflict of Interest Policy) am/are a lobbyist for:
I (or members of my family as specified in the Conflict of Interest Policy) am/are a duly elected or appointed official as noted below:
I have the following other potential conflicts to report:
I have no conflict of interest to report at this time.
I hereby certify that the information set forth above is true and complete to the best of my knowledge. I agree to make further disclosures if my personal interests change.
Signature: ___________________________
Name (printed): ______________________