IETF LLC Conflict of Interest Policy
The Conflict of Interest policy ensures IETF LLC Board Directors, employees, and contractors must act in the best interest of the IETF LLC.
Who is a Covered Individual? The IETF Administration LLC (“IETF LLC”) Board Directors, employees and contractors, as well as any volunteers and/or agents who are formally authorized to act on behalf of IETF LLC in some capacity and are considered by the LLC to be acting in that capacity (collectively, “Covered Individuals”).
Who is not a Covered Individual? IETF participants, IRTF participants, IESG members, the IRTF Chair, IAB members, IAB program members, working group chairs, research group chairs, directorate participants, the Independent Submissions Editor, the Independent Submissions Editorial Board, NOC volunteers, Tools team volunteers, the Ombudsteam, the Sergeants-at-arms, trustees of the IETF Trust, and any individual not involved in the IETF, except if such individuals are formally authorized as Covered Individuals (such as an IETF LLC Board Director).
Covered Individuals must act in the best interest of IETF LLC. Occasionally this duty may be—or may appear to be—incompatible or in conflict with a Covered Individual’s personal interests (including interests of their family members), or the interests of an organization of which the Covered Individual is an employee, director, owner, or otherwise has business or financial interest. If this occurs, or if for any other reason a Covered Individual is unable to make unbiased or impartial decisions in connection with their IETF LLC activities, the Covered Individual has a potential conflict of interest that must be documented, disclosed, addressed, avoided, and/or eliminated.
For purposes of this policy and related disclosures, "family" means a spouse, domestic partner, child, sibling, parent, stepchild, stepparent, and mother-, father-, son-, daughter-, brother-, or sister-in-law, and any other person living in the same household, except tenants and household employees.
To avoid the risk of any improper conduct or potential for conflicts, the following actions, relationships, or transactions are prohibited:
- Covered Individuals shall not use IETF LLC’s staff, services, equipment, materials, resources, or property for personal or third-party gain.
- Covered Individuals shall not engage in any outside business, professional conduct, or other activities that are directly adverse to the interests of IETF LLC.
- Board Directors (and their families) may not receive direct compensation for providing goods or services to IETF LLC, whether as paid contractors, paid advisors, paid employees, or through a financial interest in a party (such as ownership, but not including employment) that enters into a transaction with the IETF LLC.
Disclosure of Actual or Potential Conflicts
In addition to the obligation that all Covered Individuals adhere to the IETF LLC’s Code of Conduct, the IETF LLC requires that all Covered Individuals promptly disclose to the IETF LLC Board facts or circumstances that could constitute or be perceived to be a potential conflict of interest.
In the event a Covered Individual discloses a potential conflict of interest, non-conflicted Board Directors will review all disclosures and determine an appropriate resolution. Pending the Board’s review and resolution of a potential conflict of interest, disclosing Covered Individuals will conduct themselves so as to minimize the possible impact of the potential conflict of interest on IETF LLC. Each Covered Individual agrees to comply with the resulting determination of the Board, including recusal from participation in certain IETF LLC matters, termination of the conflict-related activity, termination of the engagement with the IETF LLC, or other action as directed by the IETF LLC Board.
A Covered Individual should complete the attached Conflict of Interest Disclosure Form to fully and completely disclose the material facts about any potential conflicts of interest. This Disclosure Form shall be submitted to the IETF LLC Board on each of the following events:
- Upon a person’s initial association with IETF LLC.
- On an annual basis established by the IETF LLC Board.
- At any time that change occurs after a Form has been submitted. In this case, Covered Individuals must disclose potential conflicts of interest as soon as they are known or reasonably should be known.
At least annually, the IETF LLC Board, as one of its functions and responsibilities, will review a current copy of each Disclosure Form for the purpose of monitoring compliance with the terms of this Policy. If the Board has reason to believe that a Covered Individual has failed to disclose a potential conflict of interest, it shall inform the Covered Individual of the basis for such belief and allow the Covered Individual an opportunity to explain the alleged failure to disclose. If the Board decides that the Covered Individual has in fact failed to disclose a potential conflict of interest, the Board shall take such disciplinary and corrective action as the Board shall determine appropriate for the circumstances.
The IETF LLC Board will maintain a private repository of all disclosures and associated resolutions. The IETF LLC Board will also publicly publish a summary of disclosures and resolutions, both as summary statistics (e.g. total number of disclosure forms received) as well as individual-level disclosures. Confidential information and information not relevant to the business of the IETF will be redacted when individual disclosures are published. Disclosures will be posted on an annual basis, or more frequently when and if updates to individual disclosures occur.
Policy version: 1
Last updated: 31-October-2019
Please see current Conflict of Interest Disclosures here.