WBLAEF CONFLICTS OF INTEREST POLICY

1.01 Conflicts of Interest Policy (See Article IX, Sections 9.03 in the Bylaws)

a) Policy Statement For the purposes of this policy, a “conflict of interest” is any situation or activity that may directly or indirectly conflict or interfere with the mission, policies or procedures of the White Bear Lake Area Educational Foundation, Inc. (the Foundation), including but not limited to

1) engaging in any unethical or illegal practice,

2) taking any unfair advantage in business dealings,

3) buying or selling services to the Foundation to the extent that one may obtain a significant financial gain,

4) participating in transactions or relationships that might reasonably be expected to affect one’s judgment in a manner adverse to the Foundation, or

5) any other action that may give the appearance of impropriety. This policy covers all staff members, members of the board of directors, and their immediate families.

b) Procedures

1) Assets, leases, business transactions, or professional services of the Foundation. The direct or indirect financial interest in the assets, leases, business transactions, or professional services of the Foundation by a member of the immediate family of a staff member shall be disclosed by the staff member to the executive director. The executive director shall report such relationship to the president. The direct or indirect financial interest in the assets, leases, business transactions, or professional services of the Foundation by a member of the immediate family of the executive director shall be disclosed by the executive director to the president. As to any such disclosure, the president will make a determination if such relationship is de minimis and need not be reported to the board of directors, or whether such relationship should be reported to the board of directors for such action as the board of directors deems appropriate under the circumstances.

2) Members of the board of directors shall have no direct or indirect financial interest in the assets or leases of the Foundation. Members of the board of directors who are employees or partners of a business or professional firm involved in business transactions or current professional services of the 3 Foundation shall disclose this relationship to the board of directors. These members shall not participate in any discussion or any vote taken in respect to such transactions or services, and such actions shall be noted in the minutes of the meeting at which such transactions or services are approved by the board of directors.

3) The Foundation contracting with staff members, members of the board of directors or their immediate families will be discouraged.

4) A member of the board of directors shall not serve as a director concurrently with a member of his or her immediate family also serving as a member of the board of directors.

5) The Foundation will not provide any remuneration to members of the board of directors for board service.

6) Any professional services or expertise of members of the board of directors will be donated as in-kind services to the Foundation.

7) Any staff members who provide consulting services other than through the Foundation or who serve on the board of another nonprofit organization must disclose such facts to the executive director to determine if there are any potential conflicts of interest.

8) Use of the Foundation’s premises and equipment for any private business is prohibited.

9) Any staff member who is aware of a potential conflict of interest with respect to any matter coming before the board of directors or a committee shall not be present for any discussion of or vote in connection with the matter.

10) Copies of this policy and the Conflict of Interest Policy Statement for Board Members will be provided to all members of the board of directors and all staff members, and they will acknowledge the receipt of Conflict of Interest terms and policies by signing and returning to the Board a signed copy of the Conflict of Interest Statement for Board Members. (See attachment)

11) Exceptions to the Conflicts of Interest Policy can be made upon full disclosure and unanimous vote of the Board of Directors.

No board member or board committee member, or staff member, or any member of his/ her family should accept any gift, entertainment, service, loan, or promise of future benefits from any person who either personally or whose employees might benefit or appear to benefit from such board or committee member’s connection with the White Bear Lake Area Educational Foundation, unless the facts of such benefit, gift, service, or loan are disclosed in good faith and are authorized by the Board of Directors. Board and committee members are expected to work out for themselves the most gracious method of declining gifts, entertainment, and benefits that do not meet this standard.

No board or committee member or staff member should perform, for any personal gain, services to any White Bear Lake Area Educational Foundation supplier of goods or services, as employee, consultant, or in any other capacity which promises compensation of any kind, unless the fact of such transaction or contracts are disclosed in good faith, and the board or committee authorizes such a transaction. Similar association by a family member of the board or committee member or by any other close relative may be inappropriate.

No board or committee member or any member of his/her family should have any beneficial interest in, or substantial obligation to any White Bear Lake Area Educational Foundation supplier of goods or services or any other organization that is engaged in doing business with or serving the White Bear Lake Area Educational Foundation unless it has been determined by the Board of Directors, on the basis of full disclosure of facts, that such interest does not give rise to a conflict of interest.

This policy statement is not intended to apply to gifts and/or similar entertainment of nominal value that clearly are in keeping with good business ethics and do not obligate the recipient, rather it is the obligation of a board member to disclose receipt of a gift valued at $100 or more.

Any matter of question or interpretation that arises relating to this policy should be referred to the president for decision and/or for referral to the board of directors for decision, where appropriate.

ACKNOWLEDGEMENT FORM - (TO BE COMPLETED ANNUALLY BY ALL BOARD MEMBERS)

Date

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Name

First Name

Last Name

Email

Disclose here, to the best of your knowledge: Any entity in which you participate (as a director, officer, employee) with which WBLAEF has a relationship; any transaction in which WBLAEF is a participant as to which you might have a conflicting interest; and any other situation which may pose a conflict of interest.

Signature

I have received and read the foregoing policy statement (Conflict of Interest Statement), Conflicts of Interest Policy of the White Bear Lake Area Educational Foundation, and Section 1.01 Conflict of Interest of the Foundation’s Bylaws and understand fully the facts requiring any possible question of violation.

* Required Field