The Upper Nehalem watershed council

Conflict-of-Interest Policy and Procedures

Drafted March 12, 2011

Approved May 21, 2011

This document establishes both the policy framework for the Upper Nehalem Watershed Council (UNWC) and the procedures to follow for Steering Committee members and staff to declare potential conflicts and for proper recusal from decision-making that may affect those interests. Employees and Steering Committee members have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest.


Disclosure Policy

An actual or potential conflict of interest occurs when a Steering Committee member or an employee is in a position to influence a decision that may result in personal gain or gain for a relative as a result of UNWC business dealings. For the purpose of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the Steering Committee member or employee is similar to that of persons who are related by blood or marriage.


No presumption of a conflict is created by the mere existence of a relationship with outside businesses. However, if a Steering Committee member or an employee has any influence on any material business transactions, it is imperative that he or she discloses to an officer of the organization as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties.


Personal gain may result not only in cases where a Steering Committee member, an employee, or a relative has a significant ownership in a firm with which UNWC does business, but also when a Steering Committee member, an employee, or a relative receives any gift or special consideration as a result of any transaction or business dealings involving the UNWC.


Disclosure Procedure

Disclosure should be made according to UNWC policy. Transactions with parties which have a conflict of interest can be undertaken only if all of the following are observed:

  1. The conflicted individual is excluded (i.e. recuses themselves) from the discussion and approval of such a transaction;
  2. A competitive bid or comparable valuation exists; and
  3. The Steering Committee has acted upon and demonstrated that the transaction is in the best interest of the organization.


Staff disclosures should be made to the executive director who shall determine if a conflict exists. If the executive director is the one with the conflict, then the Steering Committee shall determine whether a conflict exists.


Disclosure involving Steering Committee members should be made to the Chair. If the Chair has a conflict he or she would declare the conflict, defer to the Vice-Chair, and recuse themselves.


The Steering Committee shall determine whether a conflict exists and whether the contemplated transaction may be authorized as just, fair, and reasonable to the UNWC. The decision of the Steering Committee on these matters will rest in their sole discretion, and their concern must be the welfare of UNWC and the advancement of its purpose.