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Conflict of Interest Policy

WAC's Conflict of Interest policy was adopted on October 12 2026. A sample agreement is included below for your reference.


Article 1 — Purpose


The purpose of this Conflict of Interest Policy is to protect the interests of the Williamsburg Aquatic Club (“WAC”) when it is contemplating any transaction or arrangement that might benefit the private interest of an officer, director, or covered person, or might result in a possible excess benefit transaction. 


This policy supplements, and does not replace, any applicable state and federal laws governing conflicts of interest for nonprofit and charitable corporations.


Article 2 — Who Is Covered


This policy applies to:

  • All members of the Executive Board (President, Vice President, Secretary, Treasurer, Member-at-Large);
  • All chairpersons of standing committees
  • The Head Coach and any other staff member with authority over, or influence on, WAC purchasing, hiring, or financial decisions.


Each of the above is a “covered person” for purposes of this policy.


Article 3 — Definitions


3.1 Interested Person

Any covered person who has, directly or indirectly, a financial interest as defined below.


3.2 Financial Interest

  • A person has a financial interest if the person has, directly or indirectly, through business, investment, or family, any of the following:
  • An ownership or investment interest in any entity with which WAC has a transaction or arrangement;
  • A compensation arrangement with WAC or with any entity or individual with which WAC has a transaction or arrangement; or
  • A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which WAC is negotiating a transaction or arrangement.


“Compensation” includes direct and indirect remuneration as well as gifts or favors that are not insubstantial. “Family” includes a spouse, domestic partner, parents, siblings, children, and the swimmers in a covered person’s household.


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 Board or a committee decides that a conflict of interest exists, under the procedure in Article 4.


Article 4 — Procedures


Duty to Disclose. In connection with any actual or possible conflict of interest, a covered person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the Board members considering the proposed transaction or arrangement. Disclosure must occur before the Board acts.


Recusal from Discussion and Vote. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, the interested person shall leave the meeting while the determination of a conflict of interest is discussed and voted upon. The interested person shall not participate in, or be present for, the deliberation or the vote on the transaction or arrangement giving rise to the conflict.


Determining Whether a Conflict Exists. The remaining Board or committee members shall decide if a conflict of interest exists.


Procedures for Addressing the Conflict. The chair (or, if the chair is the interested person, the Vice President) may appoint a disinterested person or committee to investigate alternatives to the proposed transaction. After exercising due diligence, the Board shall determine whether WAC can obtain a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest. If a more advantageous transaction is not reasonably attainable, the Board shall determine by majority vote of the disinterested members whether the transaction is in WAC’s best interest, for its own benefit, and whether it is fair and reasonable. It shall make its decision as to whether to enter into the transaction in conformity with that determination.


Article 5 — Records of Proceedings


The minutes of any meeting at which a conflict of interest is addressed shall contain:

  • The names of the persons who disclosed or otherwise were found to have a financial interest, the nature of the financial interest, whether a conflict of interest was found to exist, and the Board’s decision as to whether a conflict of interest in fact existed;
  • The names of the persons who were present for discussions and votes relating to the transaction, the content of the discussion (including any alternatives to the proposed transaction), and a record of any votes taken — noting that the interested person was recused.


Article 6 — Compensation

A covered person who receives compensation, directly or indirectly, from WAC for services is precluded from voting on matters pertaining to that person’s own compensation. This applies, without limitation, to coaching staff who also hold a board or committee seat. No covered person may participate in setting or approving their own compensation or that of a family member.


Article 7 — Annual Disclosure Statements

Each covered person shall sign the Annual Disclosure Statement (attached) upon adoption of this policy, upon joining the Board, committee, or staff, and annually thereafter. The statement affirms that the person has received, read, and understands this policy and agrees to comply with it, and discloses any known financial interests.


Article 8 — Violations

If the Board has reasonable cause to believe a covered person has failed to disclose an actual or possible conflict of interest, it shall inform the person of the basis for that belief and afford the person an opportunity to explain the alleged failure to disclose. If, after hearing the response and making further investigation as warranted, the Board determines the person has in fact failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.


Article 9 — Adoption and Amendment

This policy was adopted by majority vote of the Executive Board on the date noted above. It may be amended by majority vote of the Executive Board at any regular or special meeting, provided the proposed amendment is included in the meeting agenda.


WILLIAMSBURG AQUATIC CLUB Annual Conflict of Interest Disclosure Statement

I have received and read the WAC Conflict of Interest Policy. I understand its requirements and agree to comply with it. I understand that WAC is a charitable organization and that in order to maintain its federal tax exemption it must engage primarily in activities that accomplish its exempt purposes.


Disclosure of financial interests (write “None” if not applicable):

________________________________________________________________

________________________________________________________________

________________________________________________________________


Signature

Date


Printed name

Role / seat