Conflict-of-Interest Policy
Applicability
1 Blink Foundation has adopted this Conflict-of-Interest Policy (“Policy”) to avoid and mitigate Conflicts of Interest or the appearance of Conflicts of Interest.
2 This Policy applies to all Blink Foundation Personnel, including Employees and Consultants.
3 Blink Foundation Personnel are required to abstain from acting on Blink Foundation’s behalf in matters where a Conflict of Interest, or the appearance of a Conflict of Interest, exists.
4 Blink Foundation Personnel may not accept travel, gifts, or entertainment from a third party that will unduly influence their responsibilities.
5 Blink Foundation Personnel are required to disclose before entering into the relationships, or immediately upon becoming aware of any actual or potential Conflicts of Interest.
6 This Policy applies to all Blink Foundation Personnel, including Employees and Consultants.
Definitions
Employee: Refers to an individual employed by Blink Foundation.
Conflict of Interest: Refers to when an individual has a personal interest to the extent that it affects, or might provide an incentive to affect, the individual’s performance of duties at Blink Foundation. The term Conflict of Interest includes activities that create actual or potential conflicts of interest and includes the activities that create the appearance of a conflict of interest.
Consultant: Refers to a person who has been engaged by Blink Foundation for a fee or other consideration.
General Policy
Blink Foundation Personnel should always perform their responsibilities in the best interests of Blink Foundation.
Blink Foundation Personnel should be free from influences that may benefit themselves or third-parties when working for Blink Foundation.
Blink Foundation Personnel must abstain from acting on behalf of Blink Foundation in matters where a Conflict of Interest may exist.
They should also avoid any situation that might lead their loyalties to become divided in a manner that creates a Conflict of Interest or the appearance of a Conflict of Interest.
Blink Foundation Personnel must also ensure that any work they perform outside of their duties in Blink Foundation do not conflict with Blink Foundation’s or their individual obligations, under any funding agreement, contract, or their terms of engagement with Blink Foundation.
Blink Foundation Personnel must seek prior permission from the Programme Director before agreeing to begin any of the following activities that relate to their responsibilities at Blink Foundation:
Resulting in compensation in excess of Rs. 25,000;
Appointments to a fiduciary board; or
Formal paid or unpaid advisory roles for any government or government entity.
Blink Foundation Personnel should ensure that their activities outside Blink Foundation are their own and not imputed to Blink Foundation.
If any Blink Foundation Personnel engage in activities in which they must make decisions that impact Blink Foundation (e.g., being on the board of entity making a grant to Blink Foundation or an organisation entering into a contract with Blink Foundation) must recuse themselves from any deliberations related to Blink Foundation.
Blink Foundation Personnel may not, except with advance written approval from the Programme Director, knowingly have a material interest in:
Any entity which is a supplier, or service provider to Blink Foundation;
Any organizations that directly competes with Blink Foundation; or
An organisation that directly funds the work of Blink Foundation
Explanation: “Having a material interest in a third party” may include:
Serving as a director, officer, or employee of a third party (a person or entity)
Performing work or services for, or receiving compensation (including consulting fees, substantial gifts, entertainment, services, travel reimbursement, or loans) for a third party;
Being materially indebted to a third party;
Having a personal contract or understanding with a third party
Blink Foundation Personnel are prohibited from accepting gifts valued in excess of Rs. 25,000 (“gifts”) from any individuals or organisations that Blink Foundation is or has been engaged with. Gifts may include travel, meals, lodging, entertainment, cash or cash equivalents, physical objects, or services.
Explanation: This prohibition is not intended to apply to travel, meals, entertainment, or the like for Blink Foundation work, including attendance at conferences, outreach for funding, solicitation and stewardship and research-related travel.
It is intended to apply to travel, meals, entertainment and the like (received other than from family and friends) that have no purpose for Blink Foundation or the Blink Foundation component is not significant, or the social component does not comport with the overall professional standard of avoiding actual or apparent conflicts of interest.