Conflict of Interest Policy

01Purpose

Create & Cultivate (“we,” “us,” or “our”) is a nonprofit organization recognized as tax-exempt under Section 501(c)(3) of the Internal Revenue Code, EIN 88-1557753, with its principal mailing address at 2413 Kittyhawk Dr, Plano, TX 75025-6093.

This policy protects the organization's interest when we consider a transaction that might benefit the private interest of an officer, director, or key employee, or might result in an excess benefit transaction. It supplements, and does not replace, applicable state and federal law governing nonprofit organizations.

02Who is covered

Directors, officers, members of committees with board-delegated powers, and employees with substantial influence over the organization's affairs.

03What is a conflict

A conflict exists where a covered person has, directly or indirectly through business, investment, or family:

• An ownership or investment interest in any entity we transact business with.
• A compensation arrangement with us or with any entity or individual we transact business with.
• A potential ownership, investment, or compensation interest in any entity or individual we are negotiating with.

04Duty to disclose

A covered person must disclose the existence and material facts of any actual or possible conflict to the directors and members of committees considering the proposed transaction, before it is discussed or voted on.

05Recusal and determination

After disclosure, the interested person leaves the meeting while the remaining board or committee members discuss and vote. The interested person may not vote on the matter. The board determines whether a conflict exists and whether the transaction is in the organization's best interest, is fair and reasonable, and whether a more advantageous arrangement is reasonably attainable.

06Records

Minutes record the names of persons who disclosed an interest, the nature of the interest, the board's determination, and the votes taken.

07Violations

If the board has reasonable cause to believe a covered person failed to disclose a conflict, it informs that person and gives them an opportunity to explain. If the board determines a failure to disclose occurred, it takes appropriate corrective and disciplinary action.

08Annual statements

Each covered person annually signs a statement affirming they have received, read, and understood this policy, agree to comply with it, and understand that maintaining tax exemption requires the organization to engage primarily in activities that further its exempt purposes.

09Compensation

A person who receives compensation from the organization may not vote on matters concerning their own compensation. Compensation decisions are made using comparability data and documented contemporaneously.