Federal tax law and state charity law spell out various ways for private foundations to deal with conflicts of interest that involve economic interests. Conflicts of loyalties present ethical issues that tax and charity laws do not reach. This conflict-of-interest policy addresses both forms of conflict.

Columbia Foundation (CF) encourages its directors, officers, and employees to play an active role in the community by serving as board members or otherwise being involved with a wide spectrum of organizations. This means that potential conflicts of interest or the appearance of such conflicts will inevitably rise. It is the foundation’s policy to address such conflicts as openly as possible.

CF directors/officers/staff/program advisors/consultants are required to disclose any actual or apparent conflicts in a timely way before voting on a matter to which the conflict relates.

Once such a disclosure is made, the board of directors (excluding the relevant disclosing director, if any) will determine whether the conflict is a conflict of loyalty or a conflict of economics. If the latter, the conflicted party will abstain from participation in discussion and decision on the transaction (other than to provide information of a technical nature or answer specific questions that may be raised by the board). If the former, the conflicted party is allowed to participate in the discussion and decision on the transaction.

This conflict-of-interest policy supplements the foundation’s bylaws.