The Keystone Foundation

“Any individual involved in Keystone Foundation 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 the Keystone Foundation's programs and services (e.g., educational courses) or its operations (e.g., contracts with third parties). In particular, participants in Keystone Foundation-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 Foundation activities. They also have an obligation to disclose any material 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 the Keystone Foundation, 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 the Keystone Foundation. Although the Keystone Foundation primarily is concerned with potential conflicts of interest involving individuals participating directly in Keystone Foundation-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. The Board of Directors has designated the Chief Executive Officer as the Keystone Foundation's Conflicts Administrator. The Conflicts Administrator is responsible for receiving Disclosure Forms and, in consultation with the Board Chair, applicable Committee chair, and/or legal counsel, assessing the significance of a given interest or relationship to the Keystone Foundation and determining the appropriate action to be taken in response to participants' disclosures of actual, potential or apparent conflicts of interest. If the Conflicts Administrator has any existing or potential conflict of interest, he or she will disclose that conflict to the current Board Chair. The Conflicts Administrator may, in his or her reasonable discretion, appoint an appropriate staff designee to receive, review and maintain Disclosure Forms. In consultation with the Board Chair, applicable Committee chair, and/or legal counsel, the Conflicts Administrator will determine, based on the Disclosure Form and other relevant information, when an individual engaged in, or about to engage in, a Keystone Foundation-related activity or other matter under consideration has an actual, potential, or apparent conflict of interest requiring some response by the Keystone Foundation. If the individual cannot otherwise resolve the conflict, the Board Chair, Committee chair, and/or Board of Directors may require any action it deems appropriate, including, but not limited to, the following: (1) Disclosure of the interest to the other participants in the decision- or policy-making body (e.g., Board, committee). (2) Written and, in some cases, oral disclosure of the interest (e.g., to an audience at an educational session). (3) Recusal from voting on a matter and limiting the indivi”

“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.”

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