Description
Standalone conflict of interest policy for lending decisions. Covers: definitions (director, officer, employee, related party, significant interest); prohibition on loans and guarantees to insiders and their partnerships; prohibition on lending to, guaranteeing for, or investing in businesses where staff have decision-making authority over applications or directors hold a significant interest; exclusion of insiders from emergency programs with referral to partner organizations; annual declaration requirement; recusal procedure at committee and board meetings; recording conflicts in minutes; and breach handling.




