Keystone Alliance

“Any individual involved in a Keystone Alliance activity or decision-making process has an obligation to disclose any conflicting or potentially conflicting personal, professional or business interest he or she may have, directly or indirectly, with the affected activity or decision. Potentially conflicting interests may relate to Keystone Alliance's programs and services (e.g., educational courses) or its operations (e.g., contracts with third parties). In particular, participants in Keystone Alliance-related activities must disclose the positions they hold or relationships they have with other organizations or entities that may conflict, directly or indirectly, with their Keystone Alliance activities. They also have an obligation to disclose any significant financial interest in, or other relationship with, an entity having a "commercial interest" in the activity or in the outcome or deliverable of the activity. A commercial interest may exist not only where the entity's products or services are under consideration by Keystone Alliance, but also where the entity's products or services are in competition or potential competition with those under consideration or where the entity's products or services may be affected by the activity or outcome. By the disclosure of such interests, the Board of Directors or its designee(s) will be in a better position to determine whether the Participant may have an interest in conflict with the interests of Keystone Alliance. Although Keystone Alliance primarily is concerned with potential conflicts of interest involving individuals participating directly in Keystone Alliance-related activities, participants also should disclose interests or relationships of individuals with whom they directly share income (e.g., spouse, domestic partner, minor children). In addition, participants should disclose interests or relationships held by others that may affect the participant's decision-making (e.g., business partner), but only to the extent they are aware of such information. Participants do not need to determine the nature of every interest held by a sibling, business partner, etc. if they have no independent knowledge of such interests. In general, participants should err on the side of disclosure if in doubt as to whether it is required under the Policy. Participants should bring any questions regarding specific applications of the Policy to the attention of the Conflicts Administrator and/or legal counsel. Examples of relationships or interests related to Keystone Alliance which should be disclosed include, but are not limited to: Business Interests: Any employment or consulting arrangements that are current, proposed, or occurred within the previous three (3) years, that reasonably involve the interests of Keystone Alliance. Any material honoraria or other payments for seminar presentations, speeches or appearances. Financial Interests: Any material ownership interests in an entity having a commercial interest in an activity or matter under consideration by Keystone Alliance. Organizational Interests: All positions currently held or sought in Keystone Alliance (e.g., Board or committee member). A current or proposed relationship with Keystone Alliance (e.g., service provider, paid consultant, family member of consumer served by Keystone Alliance). Any leadership role in, or other relationship with, another commercial or volunteer organization or entity (e.g., board member, committee member, advisor) directly or indirectly related to Keystone Alliance. A "material" interest is one which, in view of all relevant circumstances, is substantial enough that it would, or reasonably could, affect a participant's judgment with respect to Keystone Alliance activities or transactions in which he or she is involved. The Keystone Alliance Conflict of Interest Disclosure Form is considered a part of the Conflict of Interest Policy and must be submitted by any individual participating in a Keystone Alliance a”

“(5) Replacing the individual in the affected position or activity. In most instances, disclosure of the conflicting or potentially conflicting interest will itself suffice to protect Keystone Alliance's interests. In other words, once a conflict is fully disclosed to the relevant parties, they generally will be able to evaluate the possible influence of the disclosed interest. In situations where disclosure does not adequately deal with actual or potential problems, however, additional steps as described above may be necessary. All participants in Keystone Alliance-related activities must comply with the Keystone Alliance Conflict of Interest Policy by completing the Conflict of Interest Disclosure Form on an annual basis. It is the responsibility of the Conflicts Administrator and disinterested members of the Board of Directors, in consultation with legal counsel, to interpret and apply this Policy, and the Board and its designee(s) should use their best judgment in doing so.”

“Keystone Alliance determines the compensation for the CEO, Executive Director and other top management positions through a process which includes procurement of comparability data through consultation with an independent executive compensation expert. Review of the comparability data by a Committee made up of independent members of the Board of Directors to ensure that all elements of total compensation are competitive and reasonable given the nature, mission, and operations of the organization and of the individual leadership roles. Contemporaneous documentation of the deliberations and recommendations of the Committee and the decisions of the full Board are appended to the official minutes of the meeting.”

“Both the CEO and CFO review a draft of the Form 990 and make the necessary revisions. The draft is then forwarded to all members of the Board of Directors for their review. Once comments and questions have been addressed, the Form 990 is finalized.”

“Keystone Alliance makes its governing documents, conflict of interest policy, and financial statements available to the public upon request.”