Conflicts of Interest

Purpose

The purpose of this Conflict of Interest Policy is to protect the interests of A Welcome Home Inc (“the Organization”) when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer, director, key employee, or other individual with decision-making authority. This policy is intended to supplement, not replace, applicable state and federal laws governing conflicts of interest applicable to nonprofit organizations.

Interested Person

Any director, officer, key employee, committee member with governing board–delegated powers, or other individual who has a direct or indirect financial or personal interest, as defined below.

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, investment, or compensation interest in, or arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangement

Compensation includes salary, consulting fees, honoraria, gifts, or other benefits.

Duty to Disclose

In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial or personal interest and all material facts to the governing board or appropriate committee

Determining Whether a Conflict of Interest Exists

After disclosure of the financial or personal interest and all material facts, and after any discussion with the interested person, the interested person shall leave the meeting while the determination of a conflict of interest is discussed and voted upon.

The remaining board or committee members shall decide if a conflict of interest exists.

Procedures for Addressing the Conflict of Interest

If a conflict of interest is determined to exist, the governing board or committee shall:

1. Disclose the conflict in the meeting minutes
2. Prohibit the interested person from voting or influencing the decision
3. Consider whether the transaction or arrangement is in the Organization’s best interest, fair, and reasonable
4. Where appropriate, consider alternative transactions or arrangements that would not give rise to a conflict

The board may approve the transaction only if it determines that the transaction is in the best interest of the Organization and complies with applicable laws and funding requirements.

Violations of the Conflict of Interest Policy

If the governing board or committee has reasonable cause to believe a member has failed to disclose an actual or possible conflict of interest, it shall inform the member and allow the member an opportunity to explain the alleged failure to disclose.

If, after hearing the response and making further investigation as warranted, the board determines the member has failed to disclose a conflict of interest, it shall take appropriate corrective action, which may include removal from decision-making roles or other disciplinary action.

Records of Proceedings

The minutes of board and committee meetings shall contain:

• The names of the persons who disclosed or were found to have a conflict of interest
• The nature of the conflict
• Any action taken to determine whether a conflict existed
• The board’s decision as to whether a conflict existed
• The names of the persons present for discussions and votes related to the conflict
• The content of the discussion, including any alternatives considered

Compensation

No voting member of the governing board shall receive compensation for services rendered to the Organization, except as permitted by law. Any compensation arrangements must be approved in accordance with this policy and applicable federal and state regulations.

Annual Statements

Each director, officer, and key employee shall annually sign a statement affirming that such person:

• Has received a copy of this Conflict of Interest Policy
• Has read and understands the policy
• Has agreed to comply with the policy
• Understands the Organization is charitable and must engage in activities that accomplish one or more tax-exempt purposes

Review of Policy

The governing board shall periodically review this policy to ensure it complies with current legal requirements and best practices for nonprofit governance.

Certification

This Conflict of Interest Policy was adopted by the Board of Directors of A Welcome Home Inc on January 1, 2024 and reaffirmed on January 1, 2026.