Conflict of Interest Policy

Article I: Purpose

The purpose of this Conflict of Interest Policy (“Policy”) is to protect the integrity, independence, and credibility of the International Association of Crime Analysts (IACA) by ensuring that conflicts of interest are properly identified, disclosed, evaluated, and managed.

All Interested Persons have a duty to act in the best interests of the IACA and must subordinate personal, professional, or third-party interests to that duty when making decisions on behalf of the association.

This Policy supports compliance with applicable nonprofit laws and fiduciary duties of care and loyalty. It applies to all individuals who can influence IACA decisions (“Interested Persons”).

Conflicts of interest are not inherently improper; however, failure to disclose or appropriately manage them may compromise IACA.

Article II: Definitions

1.  Conflict of Interest:  A Conflict of Interest exists when an Interested Person’s personal, financial, professional, or other interests could reasonably be expected to influence, or appear to influence, their loyalty, objectivity, or decision-making on behalf of IACA.

Conflicts may be:

  • Actual: Currently affecting decision-making
  • Potential: Could reasonably develop into a conflict
  • Perceived: Could reasonably appear to others as a conflict

2.  Interested Person:  Any officer, director, chairperson, committee member, employee, contractor, volunteer, or any other individual who can influence decisions of IACA.

3.  Disinterested Person:  An individual who, with respect to a specific matter, has no conflict of interest.

4.  Material Change:  A change in circumstance that could create or influence a conflict of interest.

5.  Transaction:  Any decision, action, or arrangement involving IACA, including contracts, appointments, or use of resources.

6.  Financial Interest: Any direct or indirect financial benefit that may influence judgment.

7.  Non-Financial Interest:  Any relationship or commitment that could influence actions without financial benefit.

8.  Confidential or Non-Public Information:  Sensitive information not intended for public release.

Article III: Roles and Responsibilities

IACA Treasurer (or Designee)

  • Serves as the central intake point for disclosures.
  • Conducts initial screening and risk classification.
  • Maintains documentation in a secure, access-controlled repository.
  • Notifies IACA Executive Board of disclosures that may need general oversight.
  • Refers disclosures requiring escalation to Secondary Review Panel.

Secondary Review Panel

  • Consists of at least three (3) Disinterested Persons appointed by the IACA Executive Board.
  • Members must confirm no conflict before participating.
  • Reviews referred disclosures and develops written recommendations.
  • Does not make final determinations and provides final report to IACA Executive Board.

IACA Executive Board

  • Retains final authority for all determinations and actions.
  • Reviews and votes on Panel recommendations.
  • Ensures enforcement of this Policy and general oversight for potential conflict that may arise between disclosures.

Article IV:  Disclosure Requirements

Interested Persons must:

  • Complete an annual disclosure within fourteen (14) business days of distribution.
  • Disclose actual or potential conflicts promptly upon awareness.
  • Submit updates within five (5) business days of a material change.

Failure to submit a required disclosure may result in temporary suspension of participation in IACA activities until compliance is met.

When uncertainty exists, individuals must err on the side of disclosure.

If the Interested Person is the Treasurer, disclosure shall be made to the Board President or designee.

Article V:  Intake, Assessment, and Documentation 

Timeframe:  The Treasurer (or Designee) shall screen and assess disclosures and close or refer them  within five (5) business days of their submission by an Interested Person.

A. Screening Criteria

The Treasurer (or Designee) shall screen the Interested Person’s disclosure in relation to:

  • Decision-making authority.
  • Existence of financial or personal interest.
  • Potential impact on impartiality.

B. Completeness and Clarification

The Treasurer (or Designee) shall ensure that disclosures are sufficiently complete to support review.

If a disclosure is incomplete, unclear, or appears to omit relevant information, the Treasurer (or Designee) may return the disclosure to the Interested Person with a request for additional information or clarification.

If the Treasurer becomes aware of a potential or actual conflict of interest that does not appear to be disclosed, the Treasurer may request clarification from the Interested Person and require the disclosure to be supplemented or corrected as appropriate.

The review timeline may be paused until sufficient information is provided.

C. Risk Classification

Disclosures shall be classified as Low, Moderate, or High risk (per established matrix).

RISK LEVEL INDICATORS EXAMPLES ACTION
Low (No Conflict / Minimal Risk) - No decision-making authority related to disclosed interest.
- No financial or professional benefit. 
- Relationship is incidental or remote. 		 - Individual works for a private company but has no role in vendor, sponsorship, or program decisions 
- Individual belongs to another professional association (e.g., IALEIA) with no overlapping decision-making 		 1. Accept and file.
2. Document rationale.
3. No further action required.
Moderate (Potential / Perceived Conflict) - Indirect influence possible.
- Evolving or future relationship.
- Reasonable appearance of conflict but limited decision-making role. 		 - Individual’s agency is an IACA conference sponsor, but they are not involved in sponsorship or exhibitor decisions.
-  Individual serves as an IACA instructor and also delivers similar training independently, without using IACA resources, branding, or participant lists to promote outside work. 		 1. Accept with notation.
2. Advise recusal if the matter arises.
3. Monitor for changes.
4. Refer if situation escalates.
High (Actual Conflict) - Direct connection to decision-making.
- Financial, personal or professional benefit.
- Active involvement in affected matter.
- Clear risk to impartiality. 		 - Participating in selection of a vendor, sponsor, or training provider that employs or pays the individual.
- Using IACA platforms to promote personal consulting, paid services, or external business interests. 
- Accessing or using non-public IACA information for personal, agency, or commercial benefit.  		 1. Immediate referral to a Secondary Review Panel.
2. Recommend immediate recusal.
3. Do not resolve at Treasurer level.

D. Authority and Determination

The Treasurer (or Designee) may:

  • Close low-risk disclosures.
  • Close medium-risk disclosures but notify the Executive Board for general awareness and oversight,  
  • Monitor moderate-risk disclosures, as necessary.

The Treasurer shall not determine high-risk conflicts, per section G of this Article.

E. Documentation

Upon closing a low or medium risk disclosure, the Treasurer (or Designee) shall document and preserve:

  • Nature of the disclosed interest.
  • Risk classification.
  • Rationale.
  • Actions taken.
  • Dates.

Closed and monitored disclosures shall be reported to the Executive Board at least annually via the IACA Annual Report.

F. Mandatory Referral Criteria

Any disclosure assessed as high-risk shall be immediately referred without further Treasurer (or Designee) evaluation.

Disclosures identified as medium -risk with any of the following criteria should be referred as a matter of caution and due diligence:

  • Direct financial benefit tied to a pending decision.
  • Participation in selecting an employer, vendor, or partner.
  • Personal compensation decisions.
  • Use of confidential information for personal gain.

G. Referral and Handoff

Referrals to a Secondary Review Panel by the Treasurer (or Designee) shall include:

  • Disclosure form.
  • Date of assessment and summary of interest(s) in relation to relevant indicators.
  • Risk classification.
  • Interim measures (e.g., recusal), if immediately necessary.
  • Identification of any time-sensitive matters.
  • Due date and instructions for submitting findings back to the Executive Board.

The Interested Person shall be notified about the referral by the Treasurer (or Designee) and must comply with recusal requirements under Article VII during review, as required. 

Article VI: Secondary Panel Review Process

Timeframe:  The Board-appointed Secondary Review Panel shall review the disclosure and all other relevant information and provide a written report with a determination and recommendations to the Executive Board within ten (10) business days of receipt of referral.

A. Panel Receipt and Review

The Panel shall:

  • Respond to the Treasurer (or Designee) confirming receipt of the referral.
  • Review all materials provided.
  • Evaluate additional information necessary for proper consideration.
  • Request missing or relevant details from the Treasurer and/or Interested Person, as needed.
    • The Interested Person must not participate in any discussions or activities outside of providing requested information or specific clarification of details.
    • Recusal by the Interested Person takes place from identification of potential conflict through final decision by the Executive Board.

B. Panel Review and Discussion

Upon completing a comprehensive review, the Panel must:

  • Discuss all available materials and facts, in conjunction with the original disclosure.
  • Refer to the matrix provided in Article V and determine if a different risk assessment is more appropriate.
  • Reach a majority opinion about the presence of a conflict.
  • If the panel majority agrees that a conflict exists, discuss potential mitigation strategies and/or other recommendations.

C. Panel Findings

The Panel shall complete a written report including:

  • A summary of considerations based on the totality of all details reference the disclosure.
  • A majority panel opinion refuting or supporting that a conflict exists.
    • Note the rationale for the majority opinion.
    • Present concerns raised during any dissenting opinion.
  • List recommendations for mitigation strategies.

The final report must be sent back to the Executive Board, per instructions provided during the initial referral by the Treasurer (or Designee).

Article VII: Executive Board Decision and Action

Timeframe:  The Executive Board review, vote, and notify the Interested Person of final outcome within five (5) business days of receipt of the Secondary Review Panel’s report. If an extension is necessary, the deadline will be clearly documented.

A. Executive Board Review

The Executive Board shall:

  • Confirm receipt of the final report from the Secondary Review Panel.
  • Determine presence of Interested Board members. They must recuse and:
    • Refrain from discussion, deliberation, and voting.
    • Not influence decision-making, formally or informally.
  • Review and discuss the findings presented and consider the possibility of any recommendations for conflict mitigation.
  • Assess the possibility of direct or indirect complications pertaining to implementing recommendations.
  • Make final determinations.

B. Quorum and Voting

  • Verify quorum of Disinterested Executive Board members.
  • A minimum of three (3) Disinterested Executive Board members is required.
    • If quorum cannot be achieved, the Executive Board may delegate authority to a committee or independent body composed entirely of Disinterested Persons to review and decide the matter.
    • If this action delays the deadline, a new deadline shall be set and communicated.
  • Actions require a majority vote.
  • Final actions by the Executive Board shall be updated with disclosure records retained by the IACA Treasurer (or Designee).

C. Notification

Final actions by the Executive Board shall be updated with disclosure records retained by the IACA Treasurer (or Designee).

The Interested Person shall be notified in writing by the Treasurer (or Designee), to include:

  • A summary of the determination regarding a presence or absence of conflict of interest.
  • The final decision and vote by the Executive Board.
  • Necessary information if loss of, or change to, IACA activity is deemed appropriate to avoid risk to IACA.
  • Notice of available appeals process.

D. Documentation

The Executive Board shall document the basis for all determinations in meeting records.

Article VIII: Compensation Decisions

Compensation decisions must:

  • Receive approval by Disinterested Executive Board members.
  • Exclude Interested Persons from discussion and voting.
  • Be supported by a competitive process and/or comparability data where applicable.
  • Be documented in Executive Board meeting minutes.

Article IX: Confidentiality

All disclosures and determinations are confidential.

Redacted summaries may only be provided to those parties with a legitimate governance or legal need.

Unauthorized disclosure constitutes a violation of this Policy.

Article X: Violations

Failure to disclose a known conflict or comply with this Policy constitutes a violation. The Executive Board may impose corrective actions, including:

  • Education or guidance.
  • Written warning.
  • Limitations on participation.
  • Suspension.
  • Removal from role.

For elected Board members, removal actions must follow by laws and applicable procedures.

Article XI: Appeals

Appeals must be submitted within five (5) business days and may be based on:

  • Procedural error.
  • New information.
  • Material error in judgment.

Appeals shall be reviewed by a new Secondary Review Panel of Disinterested Persons appointed by the Executive Board.

The Appeals Panel shall provide recommendations to the Executive Board, which will issue a final decision within fifteen (15) business days.

Article XII: Record Retention

All records shall be retained by the IACA Treasurer for at least seven (7) years in a secure system.

Article XIII: Use of IACA Resources

IACA resources, information, and branding may not be used for personal or external benefit without prior authorization.

Article XIV: Acknowledgment and Disclosures

All Interested Persons must acknowledge annually that they have read, understand, and agree to comply with this Policy. 

 

Updated May 2026