USATF National Office Staff Conflict of Interest Policy

November 13, 2003

MEMORANDUM TO USATF NATIONAL OFFICE STAFF

Re: Conflict of Interest policy and staff reporting requirements

In 2002 the Board of Directors passed an organizational Conflict of Interest (COI) Policy for Board members and certain other volunteers. At the same time, a similar policy for the National Headquarters staff was implemented. The purpose of this policy is to:

  • State that USA Track & Field intends to conduct its business and other activities in an open environment that is free of potential, or perceived, conflicts that might influence decisions;
  • Clearly define what activities and behaviors constitute a conflict of interest and the results of any such behavior;
  • Provide an effective mechanism to gather information about potential conflicts.

Generally, the policy is focused on a standard list of conflicts such as business arrangements (consulting contracts, etc.), gifts, and excessive hospitality. This list was developed by the Audit Committee, under the Board's direction, and is consistent with the policies of other organizations similar to USA Track & Field.

Please review the policy and its attachments. It is very important that you clearly understand the policy and comply with all reporting requirements and deadlines. This office policy is mandatory for all employees. If you have questions about the policy or compliance with specific requirements, please see the CEO as soon as possible.

The policy and attached examples refer to "nominal value" and "excessive." These are terms used in the Board's policy and can be confusing. All employees should interpret the policy to mean that all possible conflicts should be reported on the attached form to the CEO - this includes all lunches or small gifts. I realize this may increase the reporting burden on a few of you, but it is important that the National Headquarters be viewed as a leader and above reproach in this regard. This does not mean that you are not allowed to accept an occasional lunch or small gift from a vendor, event organizer or sponsor, it just means that you should report those to the CEO. This will allow the National Headquarters staff to be in complete compliance with the policy and avoid any confusion on what is or is not material.

It is important to note that you must file the attached statement on an annual basis, whether you have anything to report or not. In addition, you must file the attached statement any time throughout the year that a potential conflict arises. If the amount, frequency, or nature of any meal or gift from a vendor, sponsor, or other party becomes a concern, the CEO will meet with the individual involved prior to taking any action or reporting to the Board.

USA Track & Field, Inc. Conflict of Interest Statement

Applies to Staff and consultants

No employee of USA Track & Field (USATF) shall derive any personal profit or gain, directly or indirectly, by reason of his or her decisions or activities while employed by USATF. In addition, USATF employees should decline all gifts, discounts, excessive hospitality and other transactions due to perceived and real conflict of interest implications. Certain consultants, as determined by the CEO, are also bound by this policy. This excludes the normal compensation and benefits due each employee or contractor.

Specifically:

  • Each employee or consultant shall disclose to the CEO any personal interest that he or she may have in any business matter pending before USATF and shall refrain from participation in any discussion, evaluation, or decision on such matter. Business matters refer to vendor relationships, sponsorships, competitions/events, or other agreements.
  • USATF employees or consultants may not serve on any committee or task force of USATF except when designated by the President or CEO as "staff liaison."
  • Any employee or consultant who is an officer, board member, a committee member, employee or consultant or staff member of a USATF vendor, sponsor, event organizer or member organization shall identify his or her affiliation with such company or organization. Further, in connection with any action specifically directed to that company or organization, he/she may not participate in any discussion, evaluation or decision affecting that company or organization at the discretion of the CEO.
  • Any employee or consultant shall not accept any of the following, if more than of a nominal value, from a vendor, sponsor, event organizer or member organization of USATF: gifts, discounts, travel, excessive or inappropriate hospitality, loans or other transactions that result in a personal benefit. The determination of nominal value shall be determined by the CEO. If it is not practical to decline the gift, the item(s) shall be delivered to the CEO for company use.
  • This policy extends to prospective sponsors, vendors, event organizers or member organizations, and the affected persons are required to report, either verbally or in writing, as soon as possible and, in all cases, no later than the date of action (e.g., Board vote, contract signing).

All transactions with a vendor, sponsor, event organizer or member organization, regardless of amount or value, shall be disclosed in a written statement to the CEO as soon as reasonably possible. In the case of violations of this policy, including non-disclosure or non-allowed personal benefit, the CEO shall undertake appropriate disciplinary action as provided in the employee handbook. The CEO, at his discretion and where possible, may also terminate all contracts, agreements and arrangements with the related organization, vendor or sponsor.

USA Track & Field National Office Staff Conflict of Interest Statement:

USA Track & Field Conflict of Interest Policy

Examples of Conflicts of Interest:

  • Employment
  • Direct holdings or ownership interests (equity/stock, bonds, options)
  • Personal services contracts ("contractor" arrangements such as consulting projects)
  • Sale of goods or services to the company or organization, except for those at "arm's length" (still must be disclosed)
  • Loans
  • Provision of travel or accommodation
  • Gifts of money in any amount
  • Gifts of goods or services in excess of $25 separately or $100 in aggregate per year (all amounts must still be disclosed in your statement to the CEO)
  • Discounts not available to the general public
  • Excessive hospitality defined as meals or entertainment in excess of $25 separately or $100 in aggregate per year with the exception of meals and entertainment provided at USATF or related events that are available to other USATF staff (all amounts must still be disclosed in your statement to the CEO)
  • Illegal or other inappropriate hospitality defined as activities that may place USA Track & Field in a bad light when viewed from outside the organization

Remember, all potential conflicts must be reported.

For a list of sponsors, vendors, event organizers or others, please see the CEO.