What is a conflict of interest?

A conflict of interest can occur any time someone at MPP can make or influence a decision from which they, their family members, friends, or other affiliated organizations stand to gain at MPP’s expense.

Why does it matter?

MPP has two obligations that relate to conflicts of interest:

1. The obligation to donors to be upstanding stewards of donations and to ensure that those funds are allocated properly in the furtherance of the organization’s mission; and

2. The legal obligation to ensure that employees, executives, and board members do not receive excessive compensation.

How does this affect me?

Simple: If a decision is being made in which you have a personal stake (usually financial, but it could be non-financial), you have an obligation to make that interest known, and you may need to recuse yourself from the decision-making process itself (although you can certainly participate in some of the discussion).

Are conflicts of interest always bad?

Nope. In fact, they can be beneficial to MPP; this is referred to as a “benefit of interest.” However, because benefits of interest can create the appearance of impropriety, they must be handled carefully and with full disclosure.

Example: MPP needs to hire an employment lawyer

Scenario One: One of our board members is an employment lawyer. MPP automatically avails itself of her services and pays her the asking price.

Is this okay? Anytime MPP goes into an agreement with a “disqualified person” (someone who works at MPP, is on the board of directors, or is a family member of either), it is actually illegal to pay more than fair market value for that service. So, in this hypothetical situation, MPP would need to obtain price quotes from other attorneys to ensure that the price is fair (or better than fair). If MPP can obtain a competitive service at a lower cost, it cannot (and should not) hire the board member to provide that service.

Scenario Two: One of our board members is an employment lawyer. She offers to do the work at a significant discount, because she believes deeply in MPP’s mission.

Is this okay? Yes. In this case, MPP’s affiliation with a qualified attorney would allow us to obtain this service at less than market value, which means more donor money would be going toward MPP’s mission, with less money going toward this administrative cost. However, it’s important that discussion of this decision reflect knowledge of the possible conflict, and it’s still important to know the actual market value of the service being offered.

The Policy:

1. Act with honesty and transparency.

a. I agree to bring to light any conflicts or benefits of interest I have with any decision being made at MPP.

b. MPP reserves the right to require board members and senior staff to submit a written account of all possible conflicting interests, which include formal affiliations with other organizations or personal profit motive in any MPP transaction.

2. Act in MPP’s interest.

a. In all dealings with MPP, I agree to act appropriately with regard to conflicts of interest, including recusing myself from votes or discussions in which I have a personal financial stake.

b. I agree to always consider what impact any transaction -- whether they are conflicts of interest or benefits of interest -- will have on how MPP is perceived by the public, by our donors, and by those for whom we lobby the government.

I understand that this policy is meant to supplement good judgment, and I will respect its spirit as well as its wording.


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