Purpose
This Conflict of Interest Policy (“Policy”) protects the Gaza Palestinian American Association (GPAA), a 501(c)(3) nonprofit organization, from situations in which the personal interests of its directors, officers, or volunteers could compromise—or appear to compromise—decisions made on the organization’s behalf. As a volunteer-run organization, GPAA depends on the trust of its donors, members, and the communities it serves. This Policy is designed to maintain that trust by ensuring that all decisions are made in the best interest of GPAA and the people it serves.
Definitions
- Covered Persons: This Policy applies to all members of GPAA’s Board of Directors; its officers (Chair, Vice Chair, Treasurer, and Secretary); committee members; and any volunteer entrusted with significant authority over GPAA’s finances, programs, partnerships, or decision-making.
- Related Person: A Covered Person’s spouse, parent, child, sibling, or in-law; any household member; and any business, nonprofit, or other entity in which the Covered Person or a family member holds a substantial ownership, leadership, or employment interest.
- Conflict of Interest: Any situation in which a Covered Person’s personal, financial, or professional interests—or those of a Related Person—could influence, or reasonably appear to influence, their judgment or actions on behalf of GPAA. This includes financial transactions, contracts, grant awards, vendor selection, hiring of contractors, and partnerships with other organizations.
Disclosure
- Annual Disclosure: Each Covered Person is asked to sign an annual written statement affirming that they have read and understood this Policy and have disclosed any actual or potential conflicts of interest known to them.
- Ongoing Disclosure: When a Covered Person becomes aware of a potential conflict at any other time—whether their own or another’s—they will promptly disclose it to the Chair of the Board, or to the Vice Chair if the Chair is the person involved.
Procedure When a Conflict Arises
- The Covered Person with a potential conflict will fully disclose the nature of the conflict to the Board of Directors.
- The Covered Person will not participate in the Board’s discussion, deliberation, or vote on the matter, except to provide background information requested by the Board.
- The remaining Board members, after considering the disclosure and any alternatives, will determine whether a conflict exists and decide on the appropriate course of action. The decision and the reasons for it will be recorded in the minutes of the meeting.
- If the conflict cannot be resolved through recusal alone, the Board may require the Covered Person to step aside from the specific project, committee, or transaction at issue.
Records
GPAA keeps written records of all disclosures and the actions taken in response. These records are retained for at least seven years, consistent with IRS recordkeeping guidance for 501(c)(3) organizations.
Annual Review
The Board of Directors reviews this Policy at least once a year to ensure that it remains effective and reflects GPAA’s actual governance and operations. Updates to the Policy will be communicated to all Covered Persons.
Legal Framework
This Policy is intended to comply with the legal and ethical standards applicable to 501(c)(3) nonprofit organizations under United States federal law and the laws of the state in which GPAA is incorporated.
Commitment to Transparency
GPAA is committed to the highest standards of integrity, transparency, and accountability. This Policy is one of several measures by which we hold ourselves accountable to our donors, our members, and the people of Gaza whom we serve.