When does prior employment or a direct business relationship no longer present a conflict of interest?
The Commission is presented with two situations by the requesting party: (1) may a Board member who has ended his or her employment with [an organization] one and one-half years ago consider a grant proposal submitted by the [organization] ? (2) if a member ended representation of a client six months ago and does not currently conduct business with the client, is there a conflict if the Board member acts on the former client’s proposal? Based on the standards identified above, a conflict of interest would be presumed if a Board member were to vote on an application for a grant of money in the situations described. The Board member’s vote could raise suspicion among the public that the action constituted inappropriate behavior in violation of his or her trust. Moreover, questions would likely emerge as to the Board member’s motivation for voting to either approve or disapprove the grant award. Further, he or she may still be in a position to be influenced by the former employer or clien