“Pray for us, for we are sure that we have a clear conscience, desiring to act honorably in all things.” (Hebrews 13:18)
A policy managing conflicts of interests is one of the most important policies a parish council can adopt. To have the most impact, the policy should be in writing and the parish council (and staff) should review the policy regularly. Often people are unaware that their activities or personal interests are in conflict with the best interests of the parish. A goal for many parishes, therefore, is to simply raise awareness, encourage disclosure and discussion of anything that may be a conflict and constantly encourage a “culture of candor.”
Observed examples of potential conflicts of interest include the following: 1) a priest who insisted that anyone renting the parish hall utilize the catering services of his son; 2) a construction manager who bid on parish construction project; 3) an insurance agent who through a parish endowment program was selling policies naming the parish as a beneficiary.
A conflict of interest policy should (a) require those with a conflict (or who think they may have a conflict) to disclose the conflict/potential conflict, and (b) prohibit interested parish council members from voting on any matter in which there is a conflict. Beyond including those two basic directives, each parish needs to determine how the parish council will manage the conflict.
Suggestions:
A copy of the Conflict of Interest Policy should be included in the manual of every parish council member and should be reviewed during the orientation of each new parish council member;
Minutes of parish council meetings should reflect when a parish council member discloses that he or she has a conflict of interest and how the conflict was managed, such as whether there was a discussion on the matter without the parish council member in the room, and that a vote was taken but that the “interested” parish council member abstained (parish council members with a conflict are “interested” – parish council members without a conflict are “disinterested”);
Very large parishes may circulate a questionnaire each year to find out whether any parish council member (or staff member) has a conflict of interest; typically the questionnaire asks parish council and staff members to disclose existing conflicts and reminds them to disclose any that may crop up in the future.
Some Conflict of Interest Policy documents for nonprofits run 10 or more pages. The one below conveys rather the spirit of the issue more than the legal implications of the issue and may be more appropriate for a parish setting, since conflict of interest issues are very rarely brought to court.
Conflict of Interest Policy
The standard of behavior at the ____ (name of the parish or organization) is that all staff, volunteers, and parish council members scrupulously avoid conflicts of interest between the interests of the ____ (name of the parish or organization) on one hand, and personal, professional, and business interests on the other. This includes avoiding potential and actual conflicts of interest, as well as perceptions of conflicts of interest.
I understand that the purposes of this policy are to protect the integrity of the ____ (name of the parish or organization) decision-making process, to enable parishioners to have confidence in our integrity, and to protect the integrity and reputations of volunteers, staff, and parish council members. Upon or before election, hiring, or appointment, I will make a full, written disclosure of interests, relationships, and holdings that could potentially result in a conflict of interest. This written disclosure will be kept on file and I will update it as appropriate.
In the course of meetings or activities, I will disclose any interests in a transaction or decision where I (including my business or other nonprofit affiliations), my family, and/or my significant other, employer, or close associates will receive a benefit or gain. After disclosure, I understand that I will be asked to leave the room for the discussion and will not be permitted to vote on the question.
I understand that this policy is meant to supplement good judgment, and I will respect its spirit as well as its wording.
Signed: Date:
Closing words
Perhaps even more than written policies, parish council members and staff leadership must establish by example and attitude an atmosphere of personal integrity. Some situations may need only a brief, informal comment to maintain that climate (example: “I know it’s only $24 but it’s important to keep our finances straight”). In others, a decision may be delayed because of the need to ensure that the decision has been made in the parish’s best interests. Each of us, by our daily words and actions, contributes to a culture of integrity and responsibility in parish service.