Disclosures
CSF is committed to integrity, transparency, and accountability in all operations. CSF requires the disclosure of actual or potential conflicts of interest, as well as any suspected misconduct, waste, fraud, or abuse. These disclosures are essential to protecting CSF’s mission and maintaining the trust of donors, partners, and regulators.
Conflicts of Interest
A conflict of interest exists when personal, financial, or professional considerations could compromise, or appear to compromise, an individual’s objectivity in performing duties for CSF.
Staff and board members must disclose any actual or potential conflicts of interest in writing to CSF’s Executive Director or Board Chair.
Contractors and subrecipients must disclose conflicts as part of their agreements with CSF.
Conflicts must be reviewed and managed to ensure no undue influence on CSF’s decisions.
Mandatory Disclosures of Misconduct
All staff, board members, contractors, and subrecipients must promptly report suspected:
Fraud, waste, or abuse of organizational or grant funds.
Violations of law, regulations, or CSF policy.
Bribery, gratuities, or other unethical practices.
Disclosures should be submitted to CSF’s Executive Director or designated Compliance Officer.
Anonymous reporting may be made through CSF’s internal reporting system, though identifying information is encouraged for effective investigation.
Protection from Retaliation
CSF prohibits retaliation against any individual who, in good faith, makes a disclosure or participates in an investigation.
Retaliation will result in disciplinary or corrective action, up to and including termination of employment or contracts.
Investigation and Resolution
All disclosures will be reviewed promptly and impartially.
Findings and corrective actions will be documented and retained in CSF’s compliance files.
When disclosures involve grant funds, CSF will comply with all funder reporting requirements and notify oversight authorities as required.
Grant-Specific Requirements
Certain grants (e.g., federal awards) may impose additional disclosure obligations, such as reporting conflicts of interest and violations of law to federal agencies.
Where applicable, CSF will issue grant-specific disclosure addenda in the Grant Portal.
Enforcement
Failure to disclose a conflict of interest or suspected misconduct may result in disciplinary action, termination of contracts, or referral to legal authorities.
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