Conflict of Interest Policy for Oberlin Shansi Trustees, Officers and Key Employees


  1. Scope.  The following statement of policy applies to each member of the Board, to each officer of Oberlin Shansi and to all Key Employees , that is the Executive Director and Associate Director, hereafter (“Covered Persons”)

  2. Responsibility.  Covered Persons serve the interests and mission of Oberlin Shansi and have an obligation to this concept.  All decisions of Covered Persons are to be made solely on the basis of a desire to promote the best interests of the organization and to achieve the goals and mission statement of Oberlin Shansi.

    Individuals inevitably are involved with the affairs of other institutions and organizations.  Effective boards and organizations will include individuals who have relationships and affiliations that may raise questions about perceived conflicts of interest.  Although many such potential conflicts are and will be deemed inconsequential, every Covered Person has a responsibility to ensure the entire Board is made aware of situations that involve personal, familial, or business relationships that could create a real or perceived conflict of interest.  Thus, the Board requires each Covered Person annually a) to be familiar with the terms of this policy; b) to disclose to the Board Chair any possible personal, familial, or business relationships that reasonably might give rise to a conflict involving Oberlin Shansi; and c) to acknowledge by his or her signature that he or she is in accordance with the letter and spirit of this policy.

  3. Disclosure of Conflicts With Respect to Potential Financial Transactions.   In the event any financial transaction involving Oberlin Shansi also involves (a) a Covered Person, or (b) an organization with which any Covered Person has any material financial interest, the Covered Person having the affiliation or interest, at the first knowledge of the transaction, shall disclose fully the precise nature of the interest or involvement.

  4. Annual List of Significant Related Entities. Each year the Executive Director shall prepare a list of “Significant Related Entities” consisting of (a) each organization which acts as a financial adviser to Oberlin Shansi, (b) each organization with or through whom Oberlin Shansi directly invests or deposits funds (but not including those organizations or entities in or through whom funds are directly invested or deposited), (c) the current auditors or Oberlin Shansi, (d) any organization or person with whom Oberlin Shansi has conducted business in most recently completed fiscal year in an amount or having a value in excess of $5,000, (e) any organization or person with whom Oberlin Shansi has conducted or expects to conduct business in the current fiscal year in an amount or having a value in excess of $5,000, and (f) any other organization or person whom the Executive Director considers to have a significant financial relationship with Oberlin Shansi.

  5. Disclosure Statement. Each year the Executive Director shall distribute to each Covered Person, including himself or herself, the current list of Significant Entities and each Covered Person shall be requested to indicate in writing whether such Covered Person has any affiliation with any of the listed Significant Related Entities, describing the nature of the affiliation. In the event there is any material change in the information contained in any annual submission by a Covered Person known to such person, such Covered Person shall promptly submit written notification of the change.

    A Covered Person will be deemed to be affiliated with any organization that may be potentially related to the financial operation of Oberlin Shansi (a) of which such Covered Person, or a member of his or her extended family, is a director, officer, trustee, partner, employee, or agent; or (b) in which such Covered Person or members of his or her extended family receive direct financial benefit from sales or services; or (c) in which such Covered Person or members of his or her extended family have a 35 percent or greater interest.

    The term “extended family” shall be deemed to include a Covered Person’s spouse, children (including legally adopted children), parents, grandparents, great grandparents, siblings (whether by whole or half blood), spouse of that individual’s siblings, children, grandchildren and great grandchildren and members of that individual’s household.

    In no way should this policy imply that Covered Persons, or any other individuals, should reveal any political, religious, ethnic, fraternal or civic affiliations.

  6. Administration. All disclosures required under this policy and amendments thereto shall be directed in writing to the Chair of the Board.  The Chair of the Board and the Executive Director shall be responsible for the administration of this policy.  Information disclosed under this policy shall be held in confidence by the persons authorized to receive and act upon it except where, in the judgment of any such persons, the best interest of the organization requires further disclosure.  The Board Chair shall report annually to the Board on the review process.

  7. Action on Potential Conflicts of Interest.  The Executive Committee of the Board shall determine what, if any, restrictions on consideration, participation or other activities shall be imposed in the case of any actual or potential conflict of interest in any proposed transaction or relationship, and a written memorandum of each such determination shall be prepared and maintained. 

  8. Advance Determinations.  Any Covered Person who is uncertain about possible conflict-of-interest in any matter may request the Executive Committee of the Board to determine whether a possible conflict exists; the Executive Committee shall resolve the question by majority vote.  If require, the question of potential conflict might be referred to counsel for an opinion prior to the Executive Committee vote.