- Purpose. Yeshivat Chovevei Torah Rabbinical School ("YCT") requires staff and members of the Board of Directors to comply with all applicable federal, state and local laws, rules and regulations pertaining to YCT's activities, to conduct themselves ethically and with integrity; and to avoid any conflict between their own interests and the interests of YCT. This Policy Statement sets forth general principles with respect to conflicts of interest and applies to all Board Members.
- Conflicts of Interest. A conflict of interest may arise where a Board Member, or a member of his or her immediate family, has a legal or beneficial interest as a member, owner, director, officer, lessor, broker or investor* in an enterprise or has a special, personal, business or family relationship with an enterprise:
- from which YCT purchases or leases services, equipment, supplies or real estate (or an interest therein); or
- which renders investment, managerial, consulting or other services to YCT;
- which has a pecuniary or business relationship with YCT.
- a Board Member of an organization which receives funds from YCT.
- Disclosure Procedures
- Each Board Member shall be required to sign an Annual Conflict of Interest Disclosure Statement not more than 90 days from the start of the fiscal year.
Any Board member who does not sign the statement within the 90 day period will not be permitted to vote on Board matters until the statement is signed
- Those Board members who believe under the following circumstances they may have a conflict of interest should promptly contact the Executive Director of YCT:
- upon finding that such Board Member or a member of his or her immediate family has an interest or possible interest in an enterprise or transaction that creates, or might create, a possible conflict of interest;
- upon entering into any relationship that might involve a conflict of interest with YCT;
Upon being notified, the Executive Director shall obtain the written opinion of YCT's Board Chair whether reasonable cause exists to conclude a conflict of interest exists.
- Action of the Board of Directors. Any Board Member who has, might have, or has disclosed, a potential conflict of interest to YCT's Executive Director shall take no part in the Board of Directors' consideration or determination of the matter.
- IRS Disclosures on Form 990.
YCT is required to disclose on its annual IRS Form 990 whether any of its officers or directors, as well as certain key or highly compensated employees and independent contractors, are related to each other through family or business relationships, and whether those persons, their family members and organizations in which they have interests have had business dealings with YCT.
Family relationships include a person's spouse, descendants and ancestors, siblings and the spouses of those persons. A business relationship will exist if one person is employed by or transacting business with the other person directly, or indirectly by an organization with which the other is associated as a trustee, director, officer, key employee, or greater-than-35% owner. Transactions in the ordinary course of either party's business on the same terms as are generally offered to the public are not required to be reported. A business relationship will also exist where two persons are each a director, trustee, officer, or greater than 10% owner in the same business or investment entity.
Business dealings with YCT are required to be reported only if they exceed certain dollar amounts (generally, $50,000 in the aggregate). Compensation payments by YCT to family members (as defined above) must be reported if the compensation exceeds $10,000. YCT Board members are to notify the Executive Director of any relationship or transaction described above.
**Investor is defined as an actual or beneficial owner of 5% or more of a publicly traded corporation or any percentage of a privately held company.
Annual Conflict of Interest Disclosure Statement - Fiscal Year 2022-2023
In keeping with the Conflict of Interest policy of Yeshivat Chovevei Torah Rabbinical School (YCT), I,
the Undersigned, do hereby attest to the following:
- I have read and understand the Conflict of Interest Policy, and
- Neither I nor any member of my family has in the past, is presently, or plans to engage in any activity that contravenes said policy, except as specifically noted below:
Note: Fully describe any activity that you believe contravenes the YCT Conflict of Interest Policy. Attach additional pages if necessary. If "none", so state.
IRS Form 990 Compliance:
Fully describe any family or business relationships with any YCT officers, key or highly compensated employees and consultants (independent contractors). In this regard, please describe if you are related to a YCT officer, key or highly compensated employee or consultant (independent contractor) or if you have a business relationship with any of those persons. If "none", so state.
Fully describe any family or business relationships with other YCT directors. In this regard, please describe if you are related to another YCT director or if you have a business relationship with another YCT director. If "none", so state.
If "none", so state.
If "none", so state.
*Note: Fully describe any activity that you wish reviewed in order to determine whether or not it contravenes the YCT Conflict of Interest policy.
If "none," so state.
The above constitutes a full and complete disclosure of all activities that either do or may contravene the YCT Conflict of Interest Policy.