Conflict of Interest Policy

I. Purpose
The Opera encourages the active involvement of its directors, officers, and employees in the community. In order to deal openly and fairly with actual and potential conflicts of interest that may arise as a consequence of this involvement, the Opera adopts the following conflict of interest policy.

II. Policy
Directors, officers, and employees are expected to use good judgment, to adhere to high ethical standards, and to conduct their affairs in such a manner as to avoid any actual or potential conflict between their personal interests and those of the Opera. A conflict of interest arises when a person involved with an organization in a position of responsibility, may benefit financially from a decision he or she could make in such a capacity, including indirect benefits to family members or businesses with which the person is closely associated. For this purpose, a conflict of interest does not include questions involving a person’s competing or respective duties to the organization and to another organization, such as by serving on the boards of both organizations that do not involve a material financial interest of, or benefit to, such person. Both the fact and the appearance of a conflict of interest should be avoided.

III. Procedures
Each senior staff member shall disclose in advance to the chief financial officer all material financial transactions involved the Opera and that person or his/her family. A director shall promptly disclose to the secretary of the board all material facts regarding the director’s actual or potential material financial transaction with the Opera.

IV. Annual Statements
Each director, officer and senior staff employee (or his/her family) who is involved with a material financial transaction with the Opera shall sign an Annual Disclosure Statement which discloses the details of such transaction.

V. Periodic Reviews
To ensure that the Opera operates in a manner consistent with its charitable purposes and its status as an organization exempt from federal income tax, the Board shall authorize and oversee a periodic review of the administration of this conflict of interest policy. The review may be written or oral. The review shall consider the level of compliance with the policy, the continuing suitability of the policy and whether the policy should be modified and improved.