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Policies

Conflict of Interest Policy: Downtown Boston Neighborhood Association

Last Updated February 2024

The purpose of this Conflict of Interest Policy is to protect the integrity and ensure the ethical operation of the Downtown Boston Neighborhood Association (hereinafter referred to as “DBNA or "the Organization"). This policy is designed to help DBNA leaders, all of whom are volunteers and have other professional and civic commitments and affiliations (hereinafter referred to as “the Leadership Team” or “Leadership”), identify situations that give rise to actual or potential conflicts of interest and to provide a procedure to appropriately manage such conflicts on an as needed basis.

Definitions

Conflict of Interest: A conflict of interest occurs when an individual’s personal interests, direct or indirect, interfere or might interfere with the interests of the Organization or an entity or organization by which he or she is employed. This can occur in ways that might affect an individual’s ability to make impartial decisions.
Family Member: For the purposes of this policy, a family member is defined as a spouse, parent, child, sibling, or any other relative or partner if the latter resides in the same household as the individual.
Financial Interest: A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:

An ownership or investment interest in any entity with which the Organization has a transaction or arrangement,
A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement, or
A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangement.

Procedures

Duty to Disclose
In connection with any actual or potential appearance of conflict of interest, an interested person must disclose the existence and nature of their financial interest or other such conflict of interest to the Leadership of the Organization, which will consider all facts and circumstances related to the proposed transaction, arrangement, or policy matter.

Determining Whether a Conflict of Interest Exists
After disclosure of the financial interest or other potential conflicts, and all material facts, and after any discussion with the interested person, the interested party shall leave the meeting while the determination of a conflict of interest is discussed by the remaining members of the Leadership Team. The remaining Leadership Team members shall decide if a conflict of interest exists and communicate its findings to the interested party. To the extent a conflict of interest is found to exist or is perceived to exist, the interested party shall recuse him/herself from the matter at hand and shall not influence, comment, or take a position on behalf of the Organization.

Procedures for Addressing the Conflict of Interest

An interested person may make a presentation at Leadership Team meetings, but after such presentation, they shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement that results in the conflict of interest.
A non-conflicted member of the Leadership Team shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement as needed.
After exercising due diligence, the Leadership Team shall determine whether the Organization can arrive at a decision without engaging the potentially conflicted party. To the extent this is not possible, the Organization and interested party shall work together to explore whether it is necessary to seek consent from the interested party’s employer to avoid a perceived or actual conflict of interest.
In addition to any law or regulation that may govern a Leadership Team member’s conduct related to an actual or perceived conflict of interest, a Leadership Team member determined by the Leadership Team to have a conflict of interest on a matter:
- May not represent DBNA on the matter before city, state, county, federal, or other agencies, elected officials, or their staff (the member is always permitted to represent their own personal interest in the matter, so long as they disclaim that their representation is on their own behalf, not on behalf of DBNA)
- May not speak to the media about the matter on behalf of DBNA (the member is always permitted to speak on their own behalf, so long as they disclaim that their comment is on their own behalf, not on behalf of DBNA)
- May not sign letters on behalf of DBNA related to the matter (the member is always permitted to personally comment on any matter, so long as they disclaim that their communication is on their own behalf, not on behalf of DBNA)
- May lead a DBNA meeting or event with the matter on the agenda, but must avoid sharing personal opinions on the matter while leading the meeting, and should defer as needed to another member of the Leadership Team to address the particular matter during the meeting or event to avoid the appearance of a conflict of interest

MA Conflict of Interest Law & State Ethics Commission
If a member of the Leadership Team is subject to the Massachusetts conflict of interest law or required to comply with other state ethics laws or regulations, they must disclose this to the Leadership Team. The member is solely responsible for complying with all laws and regulations; it is recommended to request advice from the State Ethics Commission to address any questions to ensure compliance.

Records of Conflict of Interest Proceedings
To the extent an actual or perceived conflict of interest is identified, the Organization will document the nature of said conflict. Such documentation shall include the names of the persons who disclosed or otherwise were found to have a financial or other interest in connection with an actual or possible conflict of interest, the nature of the interest, any action taken to determine whether a conflict of interest was present, and the LeadershipTeam’s decision as to whether a conflict of interest in fact existed. The names of the persons who were present for discussions and votes relating to the transaction, arrangement, or policy the content of the discussion, including any alternatives to the proposed transaction, arrangement, or policy, and a record of any votes taken in connection with the proceedings.

Annual Statements
Each member of the leadership team shall annually sign a statement which affirms such person:

Has received a copy of this conflicts of interest policy,
Has read and understands the policy,
Has agreed to comply with the policy, and
Understands the Organization is a volunteer-led, civic organization that must maintain independence and avoid actual or perceived conflicts of interest in order to achieve its mission

Periodic Reviews
To ensure the Organization and its Leadership Team members do not engage in activities that could be seen as an actual or perceived conflict of interest, periodic reviews shall be conducted by the Leadership Team.

This policy shall be reviewed annually by the leadership team and may be amended from time to time as necessary to ensure compliance with legal requirements and the ethical operation of the Organization.

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