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Conflict of Interest Policy

Safeguarding impartial decisions and public trust in our work.

All Policies Report a Concern

1) Purpose

Digital Safe‑Havens Network (DSN) requires decisions to be made solely in the best interests of the organization and its beneficiaries. This policy helps identify, disclose, and manage actual or potential conflicts of interest involving directors, officers, employees, advisors, contractors, and volunteers (“Covered Persons”).

2) Definitions

  • Conflict of Interest: A situation where personal, financial, or other interests could improperly influence (or appear to influence) a Covered Person’s judgment or actions on behalf of DSN.
  • Related Party / Family: Spouse, domestic partner, ancestors, siblings, children, grandchildren, and their spouses/partners; or an entity in which a Covered Person has a material financial interest or managerial role.
  • Financial Interest: Any direct or indirect ownership, compensation arrangement, or potential benefit from a transaction or arrangement with DSN.

3) Disclosure Obligations

  • Covered Persons must disclose any actual, potential, or perceived conflict to the Secretary (or Ethics/COI designee) before DSN deliberates or acts.
  • Board members must file an annual COI statement and update it within 30 days of any material change.
  • Staff and volunteers disclose via onboarding forms and update as needed.

4) Evaluation & Recusal Procedures

  1. Presentation: The Interested Person may present facts but must then leave the meeting during discussion and voting.
  2. Independent Deliberation: Disinterested members evaluate whether a conflict exists and whether a proposed transaction is fair and in DSN’s best interest.
  3. Alternatives: When applicable, obtain comparable alternatives to ensure terms are reasonable and at or below market.
  4. Vote: Only disinterested members vote; outcomes and recusals are recorded in the minutes.

5) Related‑Party Transactions

DSN may not enter into a related‑party transaction unless the board (or authorized committee) determines it is fair, reasonable, and in DSN’s best interest. Competitive bids or independent valuations are encouraged where feasible.

6) Gifts, Hospitality & Other Benefits

  • Covered Persons may not solicit gifts and may accept only nominal (de minimis) unsolicited items that do not influence actions.
  • Cash or cash‑equivalent gifts are prohibited.
  • Travel or hospitality offered in connection with DSN work must be pre‑cleared when it exceeds de minimis value.

7) Confidentiality

Information learned through DSN service must not be used for personal advantage or disclosed improperly. Confidential data must be safeguarded consistent with DSN’s Data Protection and Whistleblower policies.

8) Recordkeeping

  • Minutes reflect disclosures, recusals, alternative options considered, and vote results.
  • COI statements and determinations are retained per DSN’s records schedule.

9) Annual Statement

Each Covered Person must annually affirm that they have received, read, and agree to comply with this policy and that DSN is a charitable organization that must primarily operate for exempt purposes.

10) Violations

  • Suspected violations should be reported to ethics@digitalsafehavens.org or via the Whistleblower Policy.
  • Retaliation is prohibited. Violations may lead to corrective action up to removal or termination, and referral to authorities when warranted.

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