Conflict of Interest Disclosure for SCORE Volunteers

Purpose

SCORE volunteers are expected to act with integrity, objectivity, and loyalty to SCORE’s mission. Volunteers must avoid actual or perceived conflicts of interest between their personal interests and the interests of SCORE or its clients.  This page explains:

• What constitutes a conflict of interest
• Activities that are prohibited or permitted under SCORE policy
• When and how to disclose a conflict
• How SCORE reviews and responds to disclosures

Transparency protects SCORE, its clients, and its volunteers. Disclosure is required whenever a reasonable question of conflict exists.  Disclosure is not punitive and does not automatically disqualify a volunteer from service.  The option to recuse yourself is available should there be a conflict of interest or the appearance of one.

What Is a Conflict of Interest?

A conflict of interest exists when a volunteer’s outside activities, relationships, or roles could interfere with, or reasonably appear to interfere with, their ability to act in the best interests of the SCORE Association, its clients, or its programs.

Conflicts may be actual, potential, or perceived. Disclosure is required even if the volunteer believes no improper action will occur.

Common Situations That May Require Disclosure

The examples below are not exhaustive. Volunteers should disclose any situation that, to the best of their knowledge, raises a reasonable question of divided loyalty, influence, or access to protected information.

1. Participation in Other Organizations Serving Similar Clients

• Serving in any capacity (volunteer, staff, board member, advisor, contractor) with an organization that provides mentoring, consulting, training, or similar services to small businesses or entrepreneurs.
• Participation in accelerators, incubators, chambers, or economic development organizations that may serve the same clients as SCORE.

2. Risk of Exposure to Protected Client Information

• Any role in another organization where SCORE client information (including client lists) could be accessed, shared, inferred, or misused.
• Situations where confidential or proprietary information obtained through SCORE could benefit another organization or individual.

Example: A situation where a SCORE mentor is sharing SCORE client lists with another organization would be a clear conflict.

3. Fundraising or Development Roles Outside SCORE

• Serving in a fundraising, sponsorship, or donor cultivation role for another organization where:
  • The organization competes with SCORE for funding, sponsors, or partners, or
  • The role could conflict with SCORE’s fundraising priorities or responsibilities.

4. Relationships with SCORE Partners or Vendors

• Holding a role (paid or unpaid) with an organization that is a current or prospective:
  • Financial partner
  • Sponsor
  • Vendor
  • Strategic partner
• Ownership, financial interest, or decision-making authority in entities that do business with SCORE.

5. Financial or Personal Interests

• Recommending products, services, or vendors in which they, their family members, or close associates have a financial or controlling interest.

See the SCORE Code of Ethics’s FAQ page for examples.

When in doubt, disclose. Disclosure protects both the volunteer and SCORE.

Note: Activities That Are Not Permitted

Under SCORE policy, volunteers may not:

• Recommend products, services, or vendors in which they, their family members, or close associates have a financial or controlling interest.
  
   
• Solicit SCORE clients to become personal customers, business partners, or investors.
  
   
• Become an officer, director, shareholder, investor, or partner of any for-profit SCORE client, or provide direct funding to any SCORE client they have mentored or supported through SCORE.
  
   
• Accept compensation, gifts, commissions, fees, travel reimbursements, or other items of value from clients or third parties in exchange for SCORE services or product recommendations.
  
   

These activities are prohibited regardless of whether a disclosure is submitted.

NOTE: Activities That May Be Permitted

Volunteers may engage in the following activities, provided no personal benefit is received and no conflict exists:

• Participate in the vetting, recommendation, or support of SCORE partners, tools, or sponsors when aligned with SCORE’s mission.
  
   
• Promote SCORE-approved resources or partnerships during authorized SCORE activities.
  
   
• Serve on nonprofit boards, provided:
  
   
  • There is no personal financial gain, and
  • The role does not create a conflict with SCORE clients (for example, mentoring a client who applies for funding from that nonprofit).
    
     

If uncertainty exists, disclosure is required.

When Disclosure Is Required

Volunteers are expected to submit a disclosure whenever a perceived conflict arises, including:

• When starting a new outside role or relationship
• When responsibilities change in an existing role
• When circumstances evolve that could create a new conflict

Disclosure is not punitive and does not automatically disqualify a volunteer from service.

How to Disclose a Conflict of Interest

1. Complete the Conflict of Interest Disclosure Form
   • The disclosure form is available as a Google Form linked on this page.
2. Submit the Form Promptly
   • Volunteers should submit the form as soon as a potential conflict is identified.
3. Review by SCORE HQ
   • All disclosures are reviewed by SCORE Compliance and the SCORE Executive Director.

SCORE Volunteer Conflict of Interest Disclosure Form: 

https://docs.google.com/forms/d/e/1FAIpQLSdrvPaCAt8ulpHgO7EFTJ7txag4t0umDcVitZfrnBjvYLIcNw/viewform?usp=header  

Review Process and Outcomes

After submission:

• SCORE Compliance and the Executive Director will review the disclosure and determine whether any action is required.
• If no response is received within 10 business days, the volunteer may assume:
  • The disclosed conflict is acceptable, and
  • No further action is required at that time.

If additional steps are needed, the volunteer will be contacted. Possible outcomes include:

• Request for additional information
• Development of a conflict of interest management plan
• Special conditions or limitations on certain activities
• Escalation of the matter to SCORE leadership or the Board of Directors, if appropriate

Volunteers will always be notified if further action, clarification, or restrictions are required.

Ongoing Responsibility

Volunteers have a continuing obligation to:

• Act in accordance with SCORE’s Code of Ethics
• Avoid misuse of confidential or protected client information
• Update their disclosure if circumstances change

Failure to disclose a known conflict may result in corrective action.

Questions or Concerns?

If you are unsure whether a situation constitutes a conflict of interest, or need assistance with disclosure, contact:

help@score.org or contact SCORE Compliance directly.

SCORE appreciates your commitment to transparency and ethical service.