Conflict of Interest Policy

Sticky Culture is committed to transparency, integrity, and accountability in all our operations. We maintain clear boundaries between our nonprofit activities and the operations of Sticky Co., a for-profit company with overlapping leadership and shared resources. To create public trust and ensure compliance with legal and ethical standards, we have established the following Conflict of Interest Policy.

Purpose

This policy exists to:

1. Prevent actual or perceived conflicts of interest between Sticky Culture and Sticky Co.
2. Ensure that Sticky Culture’s resources are used solely to further its nonprofit mission.
3. Maintain the trust of our donors, partners, and the broader community.

Scope

This policy applies to Sticky Culture’s board members, officers, employees, and contractors, and to any other individuals with decision-making authority. It covers conflicts arising from positions held or financial interests in Sticky Co., and from any other organization or relationship that could compromise, or appear to compromise, their responsibilities to Sticky Culture.

Key Principles

Independent Nonprofit Mission

Sticky Culture operates exclusively to advance its nonprofit mission. All decisions are made independently of Sticky Co.’s for-profit interests.

Fair and Transparent Cost Sharing

Sticky Culture and Sticky Co. share space, staff, and other resources under a documented Shared Expense Allocation Guide, which allocates all shared expenses equitably based on actual use. The Guide includes:

• Tracking System: QuickBooks Online (QBO) uses “Class Tracking” to categorize expenses as Sticky Co., Sticky Culture, or Shared.
• Expense Allocation: Employee time is tracked weekly, with usage percentages averaged quarterly to allocate shared costs. Reimbursements are recorded via contra-expense accounts to ensure transparency and accurate net expense reporting.

Avoidance of Personal or Financial Gain

Individuals involved with both Sticky Culture and Sticky Co. must disclose any situation where their personal or financial interests could influence—or appear to influence—their nonprofit responsibilities.

Disclosure and Recusal Requirements

Annual Disclosure

All board members, officers, staff, and contractors must complete an annual disclosure form for the Board of Directors, identifying any relationships, financial interests, or other affiliations with Sticky Co. or other organizations that could create a conflict of interest.

Case-by-Case Disclosure

Individuals must promptly disclose any potential conflicts to the Board of Directors as they arise.

Recusal from Decision-Making

When a conflict of interest is identified:

• The individual must recuse themselves from discussions and decisions related to the matter.
• Minutes of meetings will document recusals to ensure transparency.

Prohibited Activities

• Sticky Culture will not engage in activities that primarily benefit Sticky Co. or any other for-profit entity.
• Sticky Culture’s nonprofit resources—including funds, assets, and staff time—cannot be used to further Sticky Co.’s commercial interests.

Enforcement

Sticky Culture’s Board of Directors is responsible for enforcing this policy. Violations may result in disciplinary action, up to and including termination of employment or contract, or removal from the board.

Commitment to Public Transparency

This Conflict of Interest Policy, along with the Shared Expense Allocation Guide, is available for public review upon request. If you have questions or concerns about our operations or resource allocations, please contact us at contact@stickyculture.org.

This policy may be updated periodically to reflect best practices and legal requirements. The latest version will always be accessible on our website.

Last reviewed August 3, 2026