Conflict of Interest Policy

Purpose
The purpose of this Conflict of Interest Policy is to protect the interests of First Friends of New Jersey and New York (the “Organization”) when it is contemplating entering into a transaction or arrangement that might benefit the private interests of an officer, director, employee, or volunteer of the Organization. This policy is intended to promote transparency and accountability within the Organization.

Definitions
1. **Interested Person**: Any director, officer, employee, or volunteer of the Organization who has a direct or indirect financial interest, or any personal interest, in a proposed transaction or arrangement.
2. **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.
– 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
1. **Disclosure**:
– An Interested Person must disclose the existence and nature of their financial interest or personal interest to the Board of Directors or the appropriate committee before any discussion or decision regarding the transaction or arrangement.
– Such disclosure must be made in writing and should be recorded in the minutes of the meeting.
2. **Recusal**:
– An Interested Person may not participate in discussions or votes regarding the transaction or arrangement in which they have a conflict of interest. They must recuse themselves from such discussions and votes.
3. **Determination of Conflict**:
– The Board of Directors shall determine whether a conflict of interest exists. A majority vote of disinterested Board members shall suffice to make this determination.
4. **Documentation**:
– The Organization will maintain written records of all disclosures, determinations, and actions taken regarding conflicts of interest.

Annual Statements
Each director, officer, employee, and volunteer shall annually sign a statement that affirms they have received a copy of the Conflict of Interest Policy, have read and understood the policy, and agree to comply with it.

Violations of the Conflict of Interest Policy
If the Board of Directors has reasonable cause to believe that an Interested Person has failed to disclose actual or possible conflicts of interest, it shall inform the person of the basis for such belief and provide an opportunity for the Interested Person to explain the alleged failure to disclose. If, after hearing the Interested Person’s response, the Board determines the person has failed to disclose a conflict of interest, it may take appropriate disciplinary action.

Review and Amendment
This Conflict of Interest Policy shall be reviewed periodically by the Board of Directors and may be amended as necessary.