Policy · Not-for-Profit, Charities & Associations
Section 501(c)(3) conflict of interest policy
A starting-point conflict of interest policy for an organisation described in section 501(c)(3). The IRS sample does not prescribe the terms. Adoption is not required for exemption.
- Kind
- Policy. A policy or procedure for a firm or client.
- Where it applies
- United States
- AI use
- Yellow You and the tool draft together, with you directing. You check every statement you rely on.
- Law stated as at
- 22 October 2026
- Status
- Maintained. Checked on 22 October 2026 against the 2 authorities it cites, for United States.
- Version
- 1
- Source
- Written for this library
When to use it
Use when a lawyer is preparing a conflict of interest policy for a section 501(c)(3) organisation to consider. Do not use it as Form 1023, and do not treat adoption as a condition of exemption.
Used for these tasks
- Draft a conflicts-of-interest register from the related-party papers
- Draft board-governance materials against the charity standards
Each task page says how far AI may help with the task and what the lawyer must review.
How AI may be used
Yellow: the lawyer adapts the policy to the organisation and its governing document before the board adopts it.
AI may
- Set out disclosure, recusal, minutes, compensation, and annual-statement steps for the board to consider.
- State that the IRS sample does not prescribe requirements and that adoption is not required for exemption.
- Leave names, thresholds, and disciplinary outcomes blank.
AI must not
- Do not copy the IRS sample policy as the organisation's policy.
- Do not complete or file Form 1023 or Form 990.
- Do not say that adoption of this policy produces recognition of exemption.
- Do not add a state nonprofit-corporation act. None was opened.
The lawyer checks
- Compare this text with the organisation's articles, bylaws, and any state conflict statute the lawyer selects.
- Decide whether a hospital completing Schedule C needs the sample's hospital insert, which this policy does not copy.
- Confirm compensation decisions against the instructions' description of reasonable compensation.
- Do not treat the annual statement as a filed return.
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
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The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Not-for-Profit, Charities & Associations
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- Letter of appointment for Responsible People (board members), with AI oversight paragraph (adapted from the ACNC template)
- Responsible Person suitability record under ACNC Governance Standard 4
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