Purpose:
This policy is intended to specify policies and procedures that affect finances and intake procedures for programs that are funded by grants made to VORP that include public monies.

The standards, rules, and procedures as outlined in this policy are not intended to place unreasonable restrictions on any employee or volunteer but are necessary to meet the legal requirements of some of our grantors.

VORP reserves the right to interpret, change, modify, amend, suspend, or cancel in whole or in part any of the contents of this policy. In the spirit of consensus and teamwork, the Board of Directors will attempt to inform staff of any such changes prior to implementation. However, the Board reserves the right to implement such changes without prior notice if it is deemed necessary for the successful operation of the program

Policy:
VORP is enjoined by contracts for grants that involve public money. VORP may not use this money to provide public services to those who are not legally in the United States based on laws passed by the Federal and State governments.  Most of our services are exceptions to the law as they are offered to offenders and are on behalf of offenders or juveniles. However some services must be handled in a way that respects this law. This law and policy impacts the finances and intake procedures at VORP. 

Special Fund from Donors: A fund to cover the expenses of clients who are not legally in the US and not exempt from the law must be maintained.  The accounting system must be able to identify charges to this account and services must have a value that is charged to this account.

Intake Process Changes: During the intake process by interns or staff are impacted. The new procedures for intake of each client:

1. Determine client’s exemption status and annotate in permanent file
1. The client is an exempt if they:

1. Are an offender and have been offered the choice of VORP or court or other criminal justice processes.  It is deemed that these clients are not receiving a “public service.”
2. Are under 18 years of age in your opinion or by evidence of the case documentation received.
3. Are a client by reason of some connection to an offender or juvenile.

Procedures

1. Duty to Disclose
Prior to board or committee action on a Conflict of Interest, the Interested Person must disclose the existence and nature of his or her Financial Interest or Supervisory Conflict of Interest and all material facts to the directors and members of the committees with board delegate powers considering the proposed transaction or arrangement.

2.Procedures for Addressing the Conflict of  Interest

1. an Interested Person may make a presentation at the board or committee meeting, but after such presentation, he or she shall leave the meeting while the determination of the acceptability of a conflict of interest is discussed and consensus is reached. 
2. The chairperson of the board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
3. If a more advantageous arrangement is not reasonably attainable under circumstances that would not give rise to a conflict of interest, the board or committee shall determine by consensus of the disinterested directors whether the arrangement is in VORP’s best interest and for its own benefit and is therefore acceptable.

3.Violation of the Conflicts of Interest Policy

1. If the board or committee has reasonable cause to believe that a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain.
2. If, after the response of the member and making further investigation, the board or committee determines that the member has in fact failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.