Conflict of Interest Policy

Approach

The Foundation for a Healthy Saint Petersburg (“FHSP” or “Foundation”) strives to ensure the integrity of the
work we do so that the public can be confident that we are acting in the Foundation’s best interest, with loyalty
to mission, not self-interest. In doing so, the Foundation, to the fullest extent appropriate, also seeks to seize
the advantage of its community connectivity, without suffering the disadvantages of partiality and privilege in
its decision making. And as importantly, the Foundation must always be mindful of how its policies entrench
or fail to alleviate inequity. People, communities, often have a unique culture of gifting, organizing, working,
decision making, and socializing that may challenge rigid notions of propriety. The Foundation should be aware
of, and accommodate, these differences.

Conflicts of interest are evaluated within the framework of these basic values, with the aim to maximize
participation and effectiveness, but always accountably, transparently and fairly.

Covered Persons

This Conflict of Interest Policy (“Policy”) applies to all FHSP trustees, officers, staff, committee members,
advisors, and other persons acting on behalf of the Foundation (“Covered Person”).

Conflicts of Interest

A conflict of interest exists where a dual or competing interest affects our ability to be impartial. A conflict of
interest may be actual or perceived. (A perceived conflict of interest exists where a skeptical viewer might
reasonably believe that an outside interest or relationship limits our ability to be fair and objective.)
In doing its work, the Foundation recognizes that conflicts of interest are not wrong or uncommon. But they
must be appropriately disclosed and managed.

Disclosure

All Covered Persons must complete an Interest Disclosure Form annually, or upon retention, and update the
form as circumstances change. Covered Persons should also disclose conflicts of interest that arise in specific
situations. The Foundation relies on the good judgment and integrity of persons acting on its behalf. Err on the
side of caution.

Management

The Foundation may enter into a transaction or arrangement where there is a conflict of interest. However, all
conflicts of interest must be reviewed by a disinterested party to determine their nature, scope, benefit to the
Foundation’s mission, and materiality and, if material, to develop a conflict management plan. The primary
purpose of conflict management is to ensure that the person with the conflict of interest is not unsuitably
involved in making (or influencing) the decision. A recused person may provide factual background. Sometimes
the best management plan will be avoidance and the Foundation should always consider the feasibility and
desirability of such alternative options. Every transaction or arrangement should be fair and reasonable, in the
Foundation’s best interest, and for its benefit.

Any transaction or arrangement where a material financial conflict of interest exists must be approved by a
majority of the disinterested members of the Board of Trustees.

Reporting

The Foundation shall prepare an annual Accountability Report which shall include a discussion of the
Foundation’s disclosure and management of conflicts of interest.

Source: FHSPBOT Policy Manual Policy-ConflictofInterest-7/2020