Conflict of Interest Policy

The Financial Conflict of Interest Policy (“Policy”) aims to (i) ensure that all decisions and deliberations by Empowering Latino Futures (“ELF”) are made solely to further the organization’s mission of enhancing journalism nationwide, and (ii) safeguard ELF’s integrity when engaging in any dealings—such as contracts or arrangements—that may benefit, or appear to benefit, the private interests of individuals associated with ELF.

For the purposes of this Policy, an ELF Representative refers to any director, advisory board member, financial consultant, legal advisor, or staff member of ELF.

Duty of Loyalty to ELF

Each ELF Representative has an obligation to prioritize ELF’s best interests when opportunities arise. Decisions must be made with complete dedication to the organization’s mission. Representatives are expected to act consistently with ELF’s nonprofit purpose and refrain from behavior that contradicts its objectives or tax-exempt status.

Whistleblower Policy

The ELF Board approved a Whistleblower Policy in 2024. 

Acceptance of Gifts

ELF Representatives may not accept personal gifts or favors that could influence or appear to influence their allegiance to ELF. Any gift received from a party with a vested interest in ELF or its work must be incidental and of nominal value. A single gift valued at $250 or more—or multiple gifts from the same source totaling over $250 in a 12-month period—will be regarded as substantial. Cash or gifts with conditions attached are strictly prohibited. For example, a gift intended to sway the recipient’s stance on a publication’s outcome or content is not allowed.

Disclosure of Conflicts

The following types of conflicts of interest must be promptly reported to the ELF Board of Directors by any aware ELF Representative:

(a) Any actual or perceived conflict involving a donor or subject of an ELF report/publication and an ELF Representative;
(b) Ownership of shares or financial interest in a person or entity featured in an ELF publication;
(c) Any undisclosed relationship between the subject of an ELF report and either an ELF Representative or their close family members.

Conflict Resolution Procedure

(a) If an ELF Representative, or someone closely associated with them, has a stake in a contract, activity, or transaction involving ELF, a conflict—or potential conflict—of interest exists. The involved individual (“Interested Representative”) must notify the ELF Executive Director or President of the Board as soon as possible, disclosing all relevant details regarding their connection or interest.

(b) The Board may delegate this responsibility to a designated committee to determine whether the proposed activity is fair to ELF.

(c) Once a conflict is identified, it will be scheduled for discussion at the next meeting of the Board or relevant committee. The meeting notice should include a description of the conflict to be addressed. Board or committee members will be informed that a vote will occur and that a majority vote by disinterested members present at the meeting (even if fewer than a quorum) is sufficient for approval.

(d) Every effort will be made to provide all pertinent details about the conflict to the Board or committee members before the meeting. If not feasible, the information will be presented during the meeting itself.

(e) All individuals involved in the conflict will be invited to attend the meeting, provide appropriate input, and answer questions. Independent experts may also be brought in if necessary.

(f) The conflict will be thoroughly reviewed in the presence of a quorum to ensure all members understand the situation. Conflicted members may be counted for quorum purposes but may not vote.

(g) The Board or committee will, in good faith and based on available facts, decide whether the transaction or activity is fair and in ELF’s best interest at that time.

(h) Any conflicted member(s) must abstain from voting and, if required, excuse themselves from the room during the vote.

(i) A detailed record of the meeting, including the discussion and decisions made, will be included in the official meeting minutes and shared with the full Board. These minutes will be reviewed and approved at the next scheduled meeting and retained in ELF’s official records.

(j) If the conflict continues beyond one year, the full disclosure, discussion, and voting process must be repeated annually.

Personal Loans

ELF is prohibited from issuing personal loans to, or guaranteeing personal debts on behalf of, any ELF Representative.