The following Financial Conflict of Interest Policy (“Conflict of Interest Policy”) is an effort (i) to ensure that the deliberations and decisions of Unsettled are made solely in the interest of promoting the quality of journalism, and (ii) to protect the interests of Unsettled when it considers any transaction, contract, or arrangement that might benefit or be perceived to benefit the private interest of a person affiliated with Unsettled (each, an “Unsettled Representative”). As used in this Conflict of Interest Policy, an Unsettled Representative includes any director, advisory board member, financial advisor, legal counsel, or employee.

Duty to Unsettled. Each Unsettled Representative owes a duty to Unsettled to advance Unsettled’s legitimate interests when the opportunity to do so arises. Unsettled Representatives must be faithful to Unsettled’s mission and are not permitted to act in a way that is inconsistent with the central goals of the organization and its status while reporting Unsettled stories or otherwise acting on behalf of Unsettled.

Gifts. No Unsettled  Representative shall personally accept gifts or favors that could compromise the integrity of  Unsettled’s mission. Any gifts or benefits personally accepted from a party having a material interest in the outcome of Unsettled should be merely incidental to their role as an Unsettled  Representative. No gifts should be accepted if there are strings attached. For example, no Unsettled Representative may accept gifts if he or she knows that such gifts are being given to solicit his or her support of or opposition to the outcome or content of any Unsettled publication.

Conflicts of Interest. The following are examples of conflicts of interest which must be promptly disclosed to the Unsettled Advisory Board:

(a) any real or apparent conflict of interest between a donor or the subject of an Unsettled publication or report and an Unsettled Representative;

(b) an Unsettled  Representative’s ownership of an equity interest in a person or entity that is or will be the subject of an Unsettled  publication or report; and

(c) failure to disclose to Unsettled all relationships between the subject of any Unsettled  publication or report and any Unsettled  Representative or close relatives of the Unsettled  Representative.

Conflict Procedure:

(a) If an Unsettled  Representative or party related to an Unsettled Representative has an interest in any contract, action or transaction to be entered into with Unsettled , a conflict of interest or potential conflict of interest exists. Any Unsettled Representative having knowledge that such a conflict of interest exists or may exist (an “Interested Unsettled Representative”) will so advise the Advisory Board promptly. An Interested Unsettled Representative will include in the notice the material facts as to the relationship or interest of the Interested Unsettled  Representative in the entity proposing to enter into a contract, action or transaction with Unsettled.

(b) At any time that a conflict of interest or potential conflict of interest is identified,Unsettled leadership will ensure that such conflict of interest is placed on the agenda for the next meeting. The notice of such meeting will include, to the extent available when the notice is sent, a description of the conflict of interest matter to be discussed. By notice before the meeting or at the meeting, Unsettled leadership will be advised that a vote will be taken at the meeting and that, in order to authorize the relevant contract, action or transaction, an affirmative vote of a majority of disinterested Unsettled leadership present at the meeting at which a quorum is present will be required and will be sufficient.

(d) Reasonable effort will be made to cause the material facts concerning the relationships between the individuals and Unsettled  which create the conflict to be delivered to and shared with Unsettled leadership, as applicable, prior to the meeting to enable the Unsettled leadership to arrive at the meeting prepared to discuss the issue. In the event it is not practicable to deliver the information prior to the meeting, it will be delivered to the Unsettled leadership  at the meeting.

(e) Unsettled leadership, will invite all parties to the conflict of interest to attend the meeting, to make presentations and to be prepared to answer questions, if necessary. Unsettled leadership or the Committee, as applicable, will also invite outside experts if necessary.

(f) At the meeting the conflict will be discussed to ensure that all present are aware of the issues and the factors involved.

(g) Unsettled leadership as applicable, must decide, in good faith, reasonably justified by the material facts, whether the action, contract or transaction would be in the best interest of Unsettled  and fair to Unsettled  as of the time it is authorized or approved.

(h) All interested parties  must abstain from voting and, if necessary, leave the room when the vote is taken.

(i) Unsettled leadership will maintain a written account of all that transpires at the meeting and incorporate such account into the minutes of the meeting and disseminate it to the full Advisory Board. 

(j) To the extent that the conflict of interest is continuing and the contract, action or transaction goes beyond one (1) year, the foregoing notice and discussion and vote will be repeated on an annual basis.

Personal Loans. Unsettled  may not loan to, or guarantee the personal obligations of, any Unsettled  Representative.

Adapted from the Institute for Nonprofit News