Knight Foundation trustees, officers and staff may not engage or appear to engage in any activity, practice or act that conflicts with the interests of the organization. 

Notwithstanding this prohibition, Knight Foundation recognizes that trustees, officers and staff are actively engaged in community and charitable activities that may, from time to time, be supported by Knight Foundation. In those instances, trustees, officers and staff must recuse themselves from promoting or voting on grants to organizations in which they, their spouses, or other close family members have an interest. When a conflict exists on an agenda item, the interested party will disclose the conflict, answer questions from other board members, and leave the room during the discussion and vote on the matter. 

On Presidential Grants, where a staff member has a conflict, the President will review and approve the grant; where the president has a conflict, the Board Chair will review and approve the grant. 

An interest is defined as holding a position as a director, officer or employee as well as holding ownership interest in the case of a for-profit grantee. All such conflicts or appearances of conflict must be disclosed prior to the decision to make a grant. 

Any grant made to an organization that employs a trustee or a close family member of a trustee, officer or staff member will include a prohibition against the use of grant funds to pay compensation to that disqualified person. 

For purposes of the self-dealing rules, a family member includes an individual’s spouse or partner. 

There may be no financial relationship between staff and trustees. Any financial relationship between staff must be approved by the president. Any financial relationship between trustees must be approved by the board chair. 

Knight Foundation will not entertain a grant request from any organization that hires an employee of the foundation who was materially involved with a grant to that organization, until a period of two years after the expiration of such grant by the foundation to that organization. The only exception to this rule is when Knight Foundation and the grantee agree to the hiring prior to the awarding of the grant. 

In the case of vendors who hire employees of the foundation who promoted their contract or worked on their account, Knight Foundation will make a diligent effort to seek an alternate vendor as soon as practical. The foundation will also seek a “no poaching” clause in all vendor contracts. 

Staff must notify the president and CEO of the foundation in advance of accepting any outside affiliations, such as board commitments. The president and CEO and chair of the board of trustees must approve any such commitment. The president and CEO of the foundation must notify the board chair in advance of his or her own possible participation in such outside activities. Trustees, officers and staff may not accept any real or perceived benefit that might be seen as influencing foundation decisions or otherwise compromising the foundation. This prohibition includes speaker fees or honoraria or any other compensation for foundation-related activities, and significant gifts from applicants, suppliers, governments or anyone else that has or may seek some benefit from the foundation. Excluded from this prohibition are gifts of nominal value, meals and social invitations that are in keeping with good business ethics. 

Trustees, officers and staff and their spouses or other close family members may not have an interest in any supplier of goods or services to the foundation. Exceptions may be made for the benefit of the foundation and only with the expressed written approval of the president and CEO or the board chair and subject to the disclosure and recusal procedures in the second paragraph of this policy. 

Confidential financial and investment information may not be used for personal gain. 

Any trustee, officer or employee whose actions or practices constitute a conflict of interest will be subject to possible disciplinary action, which may include termination. 

The president and CEO shall determine the interpretation of this policy as to all officers and staff. The board chair shall determine the interpretation of this policy as to the president and CEO and trustees. 

The secretary of the board of Knight Foundation is directed to prepare and distribute annually to all trustees, officers and staff the conflict of interest policy and a questionnaire concerning such organizations with which theytheir spouses or partners may be affiliated and to retain records according to the retention policy. Trustees, officers and staff are responsible for informing the secretary of the board of any changes in their conflict of interest status during the course of the year.