eBusiness Community Grant Program Policies

Conflicts of Interest Policy

Dialogs strives to avoid any conflicts of interest in implementing the Dialogs eBusiness Community Grant (the “Grant Program”) by making any business decisions without bias or favoritism on the part of any of its employees, officers and directors of Dialogs (each, a “Covered Person”). Each Covered Person must comply with the policies and procedures of Dialogs, maintain the confidentiality of information required in the performance of his or her duties and not use his or her position or knowledge acquired in carrying out job responsibilities and duties for personal gain or as a representative of other interests, public or private.

The following considerations serve as a guide to the types of activity by a Covered Person that might be perceived as or constitute a conflict of interest. This policy is not a substitute for good judgment or common sense.

A conflict of interest may occur if an outside interest or activity influences or appears to influence the ability of an individual to exercise objectivity or impairs the individual’s ability to perform his or her responsibilities in the best interests of Dialogs and its Grant Program. A Covered Person is considered to have a potential conflict of interest when:

He or she or any of his or her family, including his or her spouse, parent, sibling, child, stepchild, grandparent, grandchild, great-grandchild, in-law or domestic partner (“Family”) may have a direct Financial Interest or indirect interest (each defined below) as a result of the individual’s position at Dialogs. In other words, the Covered Person has the opportunity to influence Dialogs’ granting, business, administrative or other material decisions in a manner that leads to personal gain or advantage or the personal gain or advantage of his or her Family.

Financial Interest.  If a Covered Person or his her Family has a financial interest that might conflict with the interest of Dialogs in any manner (such as whether to enter into a contract with such individual or with an organization with which such individual is associated), then the individual must bring the potential conflict to the attention of Dialogs, shall provide information as requested and then refrain from deliberating or voting in any decision with respect to the matter. A Financial Interest may include direct and indirect remuneration as well as gifts or favors that are substantial in nature. A Financial Interest is not necessarily a conflict of interest. A person who has a Financial Interest may have a conflict of interest only if the appointed committee decides that a conflict of interest exists after discussing all of the facts of the matter.

Indirect Interest.  An Indirect Interest exists when a Covered Person or his or her Family is affiliated with an organization seeking to request a grant from Dialogs. Such affiliation exists if the person is a director, trustee, officer, employee, or agent of the organization, or has an unofficial role such as significant donor, volunteer, consultant, advocate or adviser.

Disclosure, Recusal and Abstention. If a Financial Interest or an Indirect Interest exists, a Covered Person must:

Duty to Disclose.  Covered Persons must disclose to Dialogs any potential or actual conflict of interest, Financial Interest or Indirect Interest and all material facts related thereto and shall provide additional information as requested. All information so disclosed will be confidential except to the extent necessary for the protection of the interests of Dialogs. Former affiliations should be disclosed for three (3) years after the term of service.

Recusal.  Any Covered Person having a Financial Interest or Indirect Interest in a proposed transaction such as a grant application must recuse himself or herself by leaving the room during the discussion, and shall not participate in the deliberation on the merits of the proposal or the vote.

Violations of the Policy.  If Dialogs has reasonable cause to believe that a Covered Person has failed to disclose actual or possible conflicts of interests, Financial Interests or Indirect Interests, Dialogs shall inform the Covered Person of the basis of such belief and afford the Covered Person an opportunity to explain the alleged failure to disclose. If, after hearing the response of the Covered Person and making such further investigation as may be warranted in the circumstances, the appointed committee determines that the Covered Person has failed to disclose an actual or possible conflict of interest, Financial Interest or Indirect Interest, Dialogs shall take appropriate action to discipline the Covered Person and further educate the Covered Person on this Policy.

Grant Review.  If a Covered Person serves on a board of, volunteers for, or otherwise participates in an organization that has or is seeking a grant from Dialogs, or if a Covered Person or his or her Family member serves as a representative of an organization that has or is seeking a grant from Dialogs, then, during Dialogs’ process of reviewing or managing a prospective or actual grant, the Covered Person may only provide information to inform a discussion about the merits of that application or active grant and the Covered Person must not be present during deliberations over a grant application, and must also refrain from voting on, influencing or exercising decision-making authority over transactions concerning such an application.

Nondiscriminatory Policy

Dialogs does not take into consideration any race, color, national and ethnic origin to all the rights, privileges, programs, and activities generally accorded or made available to by Dialogs. It does not discriminate on the basis of race, color, national and ethnic origin in administration of its policies and programs.

Dialogs believes that equal opportunity is important for the continuing success of communities. Therefore, we have a policy of inclusiveness, diversity, and equal opportunity for implementing the Grant Program. This policy applies to all Dialogs employees, volunteers, members, clients, and contractors, as well as grant recipients.

Dialogs prohibits discrimination against Grant Program applicants on the basis of race, gender, color, national origin, age, disability, sex, sexual orientation, gender identity, religion, or veteran or military status.

Further, as part of our Grant Program, Dialogs requires all businesses seeking grant funding to have a written nondiscriminatory policy adopted by the business’s governing authority that affirms the business’s commitment to include at every level of its work all segments of the community without regard to (including but not limited to) race, gender, color, national origin, age, disability, sex, sexual orientation, gender identity, religion, or veteran or military status. Applicants for the Grant Program must submit a copy of their nondiscriminatory policy to Dialogs with the application for the grant.