Conflict of Interest Policy

Policy Statement

The Navy League of Canada is committed to maintaining the highest standards of integrity, transparency, and accountability in all of its activities. Individuals acting on behalf of the Navy League must act in the best interests of the organization and avoid situations where personal, professional, or financial interests could conflict, or be perceived to conflict, with those interests.

This policy establishes requirements for identifying, disclosing, managing, and resolving conflicts of interest.

Purpose

The purpose of this policy is to:

• Protect the integrity and reputation of the Navy League of Canada;
• Ensure decisions are made objectively and in the best interests of the organization;
• Promote transparency and accountability at all levels; and
• Provide a clear framework for the disclosure and management of conflicts of interest.

Scope

This policy applies to:

• Directors and officers at the National, Division/Provincial, and Branch levels;
• Members of committees and advisory bodies;
• Volunteers and staff with decision-making authority; and
• Any individual acting on behalf of the Navy League of Canada.

Definition of Conflict of Interest

A conflict of interest occurs when an individual’s personal, professional, or financial interests interfere, or could reasonably be perceived to interfere, with their duty to act in the best interests of the Navy League of Canada.

Conflicts may be:

• Actual – a direct conflict exists;
• Potential – a conflict could arise in the future; or
• Perceived – a reasonable person could perceive a conflict, even if none exists.

Examples of Conflicts of Interest Conflicts of interest may include, but are not limited to:

• Financial interest in a company or organization doing business with the Navy League;
• Employment, consulting, or volunteer roles with organizations that have competing or overlapping interests;
• Personal or family relationships that could influence decision-making;
• Use of Navy League position, information, or assets for personal benefit;
• Participation in decisions where the individual stands to gain personally.

Duty to Disclose

1. Individuals must promptly disclose any actual, potential, or perceived conflict of interest.
2. Disclosure shall be made:

• At the time of appointment or election; and
• As soon as a conflict arises or circumstances change.

3. Disclosures shall be made in writing to the appropriate authority (e.g., Chair, President, or committee chair) and recorded in meeting minutes where applicable.

Management of Conflicts

Once a conflict is disclosed:
1. The individual shall refrain from participating in discussions or decisions related to the conflict.
2. The individual may be required to leave the meeting while the matter is discussed and decided.
3. The remaining decision-makers shall determine whether:

• The conflict can be managed with conditions;
• The individual must be recused; or
• The individual must resign from the role related to the conflict.

All decisions regarding conflict management shall be documented.

Confidentiality

Information disclosed under this policy shall be treated confidentially and shared only with those who need to know in order to manage the conflict appropriately.

Failure to Disclose

Failure to disclose a conflict of interest, or attempting to improperly influence a decision where a conflict exists, may result in corrective or disciplinary action, including:

• Removal from a position or committee;
• Suspension or termination of membership or volunteer role; and
• Further action in accordance with Navy League bylaws and applicable law.

Annual Declaration

All directors, officers, and individuals in designated positions shall complete an annual Conflict of Interest Declaration, confirming:

• Any existing conflicts; or
• That no conflicts exist to the best of their knowledge.

Relationship to Other Policies

This policy shall be read in conjunction with:

• Navy League of Canada Bylaws;
• Code of Conduct Policy;
• Financial Management and Procurement Policies; and
• Applicable federal and provincial legislation governing not-for-profit organizations.

Review

This policy shall be reviewed periodically by the National Board of Directors to ensure continued relevance and compliance with best practices.

For any questions or clarification regarding the Conflict of Interest Policy, please contact the National Office by email at national@navyleague.ca.

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April 2024