This page provides a public summary of the internal Conflict of Interest Policy that applies to all Coefficient Giving team members. The policy is updated from time to time, and this page will be updated in the future if there are material changes.
Many Coefficient team members are actively involved in, or have close personal ties to, organizations and communities whose work benefits from Coefficient’s grantmaking and operations. These connections can be helpful in giving team members useful context and information, while at the same time creating actual, potential, or perceived conflicts of interest. The goal of Coefficient’s Conflict of Interest Policy is to ensure we openly and fairly deal with situations where personal gain, gain for family members, or gain for other close relations could improperly influence decision-making or lead to the perception of unfairness at Coefficient.
Defining “Conflict of Interest”
We define a conflict of interest as an actual or perceived conflict between an individual’s private interests and their official Coefficient responsibilities. This can come up in decisions to recommend or fund grants, hiring decisions, decisions regarding vendors and procurement, personal, social or financial benefits offered based on team members’ affiliation with Coefficient, or any number of other scenarios.
Disclosing and Resolving Conflicts
Conflicts in Grant Investigation and Recommendation
Coefficient requires all individuals investigating or recommending grants — “Grant Investigators” (GIs) — engage in proactive disclosure of certain close relationships that may lead to actual or perceived conflicts of interest in the scope of the investigator’s work.
Because GIs are often closely tied to the community of other funders and grantees in their areas of focus, they have a special responsibility to proactively deal with actual, potential, or perceived conflicts of interest that may arise in their grantmaking roles. Each GI is required to maintain a list of relationships and financial interests that may come up as conflicts during grantmaking work at Coefficient. Wherever there is potential overlap with a GI’s grantmaking portfolio, they are asked to disclose family, romantic partners, close friends, providers of financial support, prior employers, professional mentors/mentees, or any other interests where a conflict of interest may arise.
GIs are required to update their disclosure lists once per year at a minimum, but are encouraged to keep their lists up to date as new conflicts arise. (The timing and frequency of updates is, to some extent, a judgment call for the team member, but as with all conflict of interest matters, we ask GIs to err on the side of disclosure.)
After reviewing these disclosures, the Coefficient legal team (in consultation with leadership and, where appropriate, the GI) recommends mitigation measures to ameliorate the conflict. This can range from disclosing the conflict to other approvers, to requiring an independent reviewer to evaluate the grant opportunity, to requiring the grant investigator to recuse themselves from the investigation altogether. The steps required will be based on the intensity of the conflict, the availability of reasonable alternative reviewers, and the actual or perceived risk of bias, impaired judgment, or perceived unfairness. In all cases, at the beginning of an investigation or renewal process, GIs are responsible for ensuring their manager and any other approvers are aware of the conflict and any required amelioration steps.
Receiving Gifts/Personal Payments
Receiving gifts: If a grantee, potential grantee, or contractor gives a gift (e.g., a bottle of wine, chocolates, nice swag) to a member of the OP team, our recommended approach is to simply refuse these if it is socially acceptable. In situations where it is not feasible to decline the gift, all gifts valued at above $50 must be disclosed. If the gift is shareable (e.g., a fruit basket), team members are encouraged to share with others.
Personal payments: Receiving a gift, honorarium, employment wages, contractor fees, etc. from a person or entity outside of Coefficient always requires prior approval. All such arrangements should be disclosed in advance, even if the terms are market rate and the team member believes the arrangement is not being offered because of their Coefficient affiliation.
Events: For team members attending non-Coefficient events, any offer of free or reduced-cost attendance or payment of travel expenses should be disclosed to the legal team for evaluation. In some cases, we may ask team members to decline the offer and charge the expenses against Coefficient’s expense policy.
Serving on Nonprofit Boards
Some of our team members serve on the boards of nonprofit organizations. The requirements of board service — including expectations of confidentiality and the “duty of loyalty” — can risk conflicting with their responsibilities at Coefficient.
As such, we generally discourage board service, especially on the boards of grantees or potential grantees. While we do allow it under certain conditions, we generally encourage would-be board members to consider acting as Board Observers or simply sharing detailed feedback.
Personal Financial Investments
Team members engaging in active personal financial investments with the ability to create conflicts are subject to an internal policy on personal financial investments. “Personal financial investments” exclude things like index funds or mutual funds, but include individual stocks as well as bets on prediction markets, impact certificates, and similar investments. In brief, all team members are prohibited from (i) trading in companies on the restricted securities list maintained by Coefficient, and (ii) trading on material nonpublic information.
Other Conflicts
In any other situation, if a potential conflict of interest arises, the conflict should be brought to the legal team, who will be responsible for the process of reviewing it and returning a decision. Team members are encouraged to disclose the conflict to their direct managers first, but this is not required. A potential conflict should generally be disclosed at the earliest point where the team member can reasonably foresee it concretely arising. Again, we encourage team members to err on the side of disclosure. While over-disclosure will never be held against a team member, failing to disclose a potential conflict of interest may be considered a performance issue.