The Keystone Foundation

“Any individual involved in a 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 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 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 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 Keystone Foundation. Although 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. 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 Foundation 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 Foundation. 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 Foundation. Organizational Interests: All positions currently held or sought in Keystone Foundation (e.g., Board or committee member). A current or proposed relationship with Keystone Foundation (e.g., service provider, paid consultant, family member of consumer served by Keystone Foundation). 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 Foundation. 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 Foundation activities or transactions in which he or she is involved. The Keystone Foundation Conflict of Interest Disclosure Form is considered a part of the Conflict of Interest Policy and must be submitted by any individual part”

“All participants in Keystone Foundation-related activities must comply with the Keystone Foundation 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. Both the President and Assistant Treasurer 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.”