Conflict of Interest Sample Policy Statement for Churches

All directors, trustees, officers, agents, and key employees of this church shall disclose all real or apparent conflicts of interest that they discover or that have been brought to their attention in connection with this church’s activities. “Disclosure” shall mean providing properly, to the appropriate person, a written description of the facts comprising the real or apparent conflicts of interest. An annual disclosure statement shall be circulated to trustees, officers, and certain identified agents and key employees to assist them in considering such disclosures, but disclosure is appropriate and required whenever conflicts of interest may occur. The written notices of disclosures shall be filed with the board chair or such other person designated to receive such notifications. At the meeting of the governing body, all disclosures of real or apparent conflicts of interest shall be noted for the record in the minutes.

An individual trustee, officer, agent, or employee who believes that he or she or an immediate member of his or her immediate family might have a real or apparent conflict of interest, in addition to filing a notice of disclosure, must abstain from

  1. participating in discussions or deliberations with respect to the subject of the conflict (other than to present factual information or to answer questions),

  2. using his or her personal influence to affect deliberations,

  3. making motions,

  4. voting,

  5. executing agreements, or

  6. taking similar actions on behalf of the organization where the conflict of interest might pertain by law, agreement, or otherwise.

A person with a real or apparent conflict of interest will be excused from all discussions or deliberations with respect to the subject of the conflict.

A member of the governing body or a committee thereof, who, having disclosed a conflict of interest, nevertheless shall be counted in determining the existence of a quorum at any meeting in which the subject of the conflict is discussed. The minutes of the meeting shall reflect the individual’s disclosure, the vote thereon, and the individual’s abstention from participation and voting.

The board chair shall ensure that all directors, trustees, officers, agents, employees, and independent contractors of the organization are made aware of the church’s policy with respect to conflicts of interest.

For a Word document to modify, click here.

This text is provided with the understanding that ECFA is not rendering legal, accounting, or other professional advice or service. Professional advice on specific issues should be sought from an accountant, lawyer, or other professional.