This policy covers MakeWay Foundation and MakeWay Charitable Society, collectively called MakeWay.

MakeWay prides itself on being an ethical organization. We have a reputation to uphold and we want to make sure our behavior and practices are sound and reflect our professionalism. MakeWay also values the many ways its employees, volunteers, contractors and board members are involved in their communities. This range of engagement inevitably leads to occasional conflicts of interest, or the appearance of conflicts of interest.

This policy sets out the process for addressing real and perceived conflicts of interest involving employees, volunteers, contractors and board members.  

Recognizing a Conflict of Interest

Employees, volunteers, contractors and board members are expected to disclose any personal, family or business interests that they have which, by creating a divided loyalty, could influence their judgment and hence the wisdom of decisions. A conflict of interest exists wherever an individual could benefit, dis-proportionally from others, directly or indirectly, from access to information or from a decision over which they might have influence, or where someone might reasonably perceive there to be such a benefit or influence.

Examples of possible conflict of interest situations include: 

▷  a board member has a personal or business relationship with MakeWay as a supplier of goods or services or as a landlord or tenant;

▷  an employee has a personal or financial relationship with a donor or project of MakeWay outside of the workplace;

▷  MakeWay employs someone who is directly related to an employee, volunteer, contractor or board member.

Conflicts of interest, real and perceived, are inevitable and should not prevent an individual from serving as an employee, volunteer, consultant or board member unless the extent of the interest is so significant that the potential for divided loyalty is present in a significant number of situations. A full and timely disclosure of any conflict, real or perceived, and implementation of safeguards appropriate to the circumstances, will generally be sufficient to manage the conflict.  

Guidelines for Implementation

1.     Employees, volunteer, contractors and board members must disclose any personal, family, or business interest that may, in the eyes of another person, influence their judgment.   This disclosure should be made to a manager or supervisor in the case of employees, volunteers and contractors and to the Chair of the Board in case of board members. 

2.     The person informed of the conflict will determine, in consultation with other employees, senior management or board members if necessary, appropriate safeguards in the circumstances. 

3.     If the person informed is unable or unwilling to determine how to manage the conflict of interest, they will inform a member of the MakeWay management team who will make a determination and communicate any action to be taken. 

4.     The Board as a whole must disclose specific conflicts of interests to staff and external stakeholders where that interest may, in their judgment, affect the reputation or credibility of MakeWay, and to disclose the Board’s procedure for operating in the presence of such conflicts.

5.     Employees, volunteers, contractors and board member will recuse themselves from  participating in any discussion or voting on matters where they have, or may be perceived  to have, a conflict of interest. Such recusals should be recorded in minutes of meetings.

6.     Any business relationship between an individual (or a company where the individual is an owner or in a position of authority) and MakeWay, outside of their relationship as an employee, volunteer, contractor or board member, must be formalized in writing and approved by their manager or supervisor, or by the Board in the case of board members or the President and CEO.

7.     It is the responsibility of the President and CEO to track and respond to any trends identified in the conflicts of interest brought to members of MakeWay’s management team or board.