WHO IS ACCREDITED?

Private Organization Accreditation

Germaine Lawrence is a residential treatment center for girls ages 12-18 with complex behavioral, psychological and learning challenges.   Girls live at our programs while receiving special education, individual, family and group therapy; psychiatric and primary medical care; and a wide variety of therapeutic activities and interventions.
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ORGANIZATION TESTIMONIAL

Family Services of the North Shore

Kathleen Whyte, Manager of Human Resources / Accreditation Coordinator

Family Services of the North Shore is about to enter our third accreditation cycle with COA. Accreditation has provided us with a framework that enables us to demonstrate accountability to our clients, our funders and our donors. There is no question that the accreditation process and COA have benefited our agency.
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Purpose

The organization earns and sustains the public trust through honest, truthful, and responsible transactions, partnerships, and relationships with individuals, communities, providers, businesses, donors, and government entities.

FOC
CA-ETH 2: Conflict of Interest

The organization prevents the enrichment of insiders and other abuses through the adoption and enforcement of a conflict of interest policy consistent with legislation, regulations, and contracts.

Interpretation: COA does not provide a definition of “conflict of interest,” and expects an organization’s policy to do so.

Note: Please see Conflict of Interest Policy and Procedure Template - Private, Public, Canadian, Network for additional assistance with this standard.

Rating Indicators
1
The organization's practices fully meet the standard as indicated by full implementation of the practices outlined in the CA-ETH 2 Practice standards.
2
Practices are basically sound but there is room for improvement as noted in the ratings for the CA-ETH 2 Practice standards.
3
Practice requires significant improvement, as noted in the ratings for the CA-ETH 2 Practice standards; e.g., 
  • Conflict of interest policy provides minimal guidance to stakeholders due to lack of specificity, significant missing elements, significant stakeholders not covered; or
  • Minor conflict of interest concerns are noted.
4
Implementation of the standard is minimal or there is no evidence of implementation at all, as noted in the ratings for the CA-ETH 2 Practice standards; e.g.,
  • Significant conflict of interest concerns have been reported.

Table of Evidence

Self-Study Evidence On-Site Evidence On-Site Activities
    • Conflict of interest policy and procedures
    • Bylaws
    • Governing body minutes
    • Governing body and/or committee meeting minutes documenting discussions of potential and apparent conflicts of interest
    • Most recent audit
    • Interview:
      1. CEO
      2. Board Chair
      3. Treasurer
      4. Advisory/Governing Body
      5. CFO/fiscal director
      6. Persons served/community members
      7. Personnel

  • CA-ETH 2.01

    A conflict of interest policy is tailored to the organization’s specific needs and characteristics, and:

    1. defines conflict of interest;
    2. identifies groups of individuals within the organization covered by the policy;
    3. addresses transactions between governing body members, advisory group members, owners, staff, volunteers, and the organization;
    4. addresses policy enforcement;
    5. provides a framework for evaluating situations that may constitute a conflict; and
    6. invests management with developing procedures that facilitate disclosure of information to prevent and manage potential and apparent conflicts of interest.

    Interpretation: The conflict of interest policy, the organization’s bylaws, and/or the board manual should require governing body or advisory group members to recuse themselves on matters where their objectivity would be compromised. The standard does not require an exhaustive list of conflict situations, but the policy should provide a framework for determining when a situation constitutes conflict.

    Interpretation: If the conflict of interest policy requires signatures of board members, staff, and/or volunteers, these signed forms should be available with the policy.
     

    Rating Indicators
    1
    The organization has implemented a conflict of interest policy as per the requirements of the standard. 
    2
    There is written policy that is accessible and followed by stakeholders, but it lacks comprehensiveness or clarity; e.g.,
    • Two of the elements are not fully addressed; or
    • One element is not addressed at all.
    3
    Practice requires significant improvement; e.g., 
    • The policy provides minimal guidance to stakeholders due to lack of specificity; or
    • Stakeholders are unaware of the policy; or
    • At least three of the elements are not fully developed or two of the elements are not developed at all.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • No policy exists; or
    • Policy is not enforced or is ignored in practice.

  • CA-ETH 2.02

    Conflict of interest policies and procedures ensure that contracts and business arrangements serve the organization’s and service recipient’s best interests, not private interests.

    Rating Indicators
    1
    The organization's practices reflect full implementation of the standard.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • Policy lacks clarity about how the separation of private interests versus organizational interests is defined and enforced, e.g., the policy does not clearly define private interests.
    3
    Practice requires significant improvement; e.g., 
    • Policy and/or procedures need significant strengthening; or
    • Stakeholders are unaware of the policy or procedures; or
    • Policy is not routinely enforced.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,
    • There is evidence of business decisions serving private interests over the best interests of the organization and service recipients.

  • CA-ETH 2.03

    Organization members, community partners, governing body and advisory group members, personnel, and consultants who have a financial interest in the organization’s assets, business transactions, leases, or professional services:

    1. disclose this information; and
    2. do not participate in any discussion or vote taken with respect to such interests.

    Interpretation: Governing body members who are part of the organization’s audit committee cannot receive compensation for professional services they provide as consultants.

    Note: Element (b) does not apply to owners in private, for-profit organizations.

    Rating Indicators
    1
    The organization’s conflict of interest policy fully addresses the requirement for disclosure of conflicts of interest and for recusal from decisions related to such interests.
    2
    Practices are basically sound but there is room for improvement; e.g., 
    • The policy and/or procedure lacks comprehensiveness or clarity regarding one of the following:
    • Applicable stakeholders; or
    • The types of transactions that require disclosure; or
    • Safeguards regarding disclosure or recusal.
    3
    Practice requires significant improvements; e.g.,  
    • Procedures do not clearly identify applicable stakeholders; or
    • Procedures do not delineate the types of transactions that must be disclosed; or
    • Safeguards regarding disclosure or recusal are insufficient; or
    • Governing body members or other important stakeholders are not aware of the policy/procedures.
    4
    Implementation of the standard is minimal or there is no evidence of implementation at all; e.g.,

    Conflict of interest violations have occurred.
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