Adoption Applicant Conflict of Interest Policy

  • Overview

    Description: The policy covers all applicants who are known to AGCI or determined to be a connected party to AGCI, who wish to pursue the adoption of a child through AGCI.

    Purpose/Rationale: To provide all parties with AGCI’s expectations around conflict of interest and when it applies.

    Applicability: All AGCI employees, volunteers, interns, board members and other connected parties.

  • Policy

    AGCI has a responsibility to ensure that all adoption activities are consistent with AGCI mission and values, ethics and policy of our licensing and accrediting bodies, and the laws of the United States, the Hague Convention on International Adoption and foreign governments.

    In our desire to assist those seeking to adopt, it is our ethical obligation to ensure that the best interests of the primary client are our first consideration followed by the confidentiality of the secondary client. To that end AGCI has established that all persons known to AGCI or viewed as connected parties will require review of their adoption application by the Special Consideration Committee.

    If an applicant is determined to fall within this policy, the applicants will be asked to sign a memo of understanding regarding the policy and the following procedures will be followed in their adoption process.

  • Definitions

    Conflict of Interest: The entanglement of an individual’s private interests with professional obligations, such that an independent observer might reasonably question whether the individual’s professional actions or decisions are improperly influenced by considerations of self-interest, a prior commitment, competing loyalties, an inability to be objective and/or personal financial impact.

    Primary Client: The child who will be adopted.

    Secondary Client: The adopting parent(s).

    Persons Known to AGCI: Past and current employees; past and current interns/volunteers; and/or former board members (at least six months from end of board commitment).

    Connected Parties to AGCI: Family members, friends or other close relationships of the above defined “persons known to AGCI,” as determined by the Special Consideration Committee.

    Family Member: Spouse, child or any relative by birth, marriage or adoption.

    Special Consideration Committee: A three-member committee; in the case that one of the committee members is the applicant or related to the applicant, that committee member will excuse themselves from the committee and be replaced by an impartial member.

  • Procedure

    Special Considerations:

    1. Applicants will be asked to adopt through a program where they have no connection to the program director(s).

    2. When the applicants are connected to the Post-Adoption Coordinator, the Director of Adoption or the Adoption Paperwork Coordinator will conduct post adoption follow-up and monitoring or will be CC’d on all communication and monitor the case more closely.

    3. When the applicants are connected to the President, Vice President of International Programs or Vice President of Adoption, that AGCI employee will assist the Special Consideration Committee in determining if the policy applies.

    4. Employees will be asked to sign a memo of understanding if an applicant is known to that employee.

    5. All applicants will have the option to appeal the decision of the special consideration committee. If such an appeal is requested the applicant will be provided with the procedure for filing an appeal.

    6. Employees or board members may request that the Special Consideration Committee decline an applicant based on the relationship with that employee or board member. This request will be held in confidence.


    1. Employees will adopt through a country where they do not have a direct connection.

    2. All employees are strongly encouraged to choose a Hague program to avoid the appearance of preferential treatment.

    3. Employees are asked to sign a memo of understanding that they will not discuss their adoption during business hours.

    4. Employees should refrain from putting colleagues into a compromising position by discussing their adoption outside of business hours.

    5. Employees may not use any working hours to conduct adoption-related business/calls.

    6. Employees will need to request PTO hours from their supervisor for all adoption related calls/business.

    7. Employees who do not follow the policy will be subject to disciplinary action, including but not limited to, a verbal or written warning.


    The Special Consideration Committee will review the application based on the current adoption guidelines and will determine if the applicants are eligible to adopt. During the review of the application all information included on the application, in addition to all information known to the Special Consideration Committee members through the applicants’ relationship to the agency may be considered in determining eligibility.

    Once general eligibility is determined, the Special Consideration Committee will determine applicants’ eligibility for specific program(s). If applicants qualify for a country that operates under the Hague convention, the Special Consideration Committee will strongly recommend the applicants adopt through this program to further reduce the perception of preferential treatment.

    Application Procedure:

    1. Add to Pre-App and Application the following question: Do you have any past or current personal and/or professional affiliation with AGCI staff, volunteers, interns or board members?
    a. This question will trigger a special consideration of the application by the Inquiry Coordinator.

    2. Inquiry Coordinator will receive pre-app or application and send out memo of understanding.

    3. Inquiry Coordinator notifies Vice President of Adoption that a “special consideration” application has been received.

    4. Vice President of Adoption will designate who will “lock” the applicants file in SAM to only the designated staff members.

    5. The Special Consideration Committee is convened by the Vice President of Adoption within five business days of receiving the application and/or supporting documents.

    6. The Special Consideration Committee determines the applicants’ agency and program eligibility and notifies the Inquiry Coordinator of the decision.

    7. Inquiry Coordinator notifies applicant of their approval/denial and which programs they are eligible for based on the special considerations.
    a. If the applicant is a staff member, the Special Consideration Committee may tell the applicant directly of the decision.

    8. If the applicants are approved, the known employee will be asked by their supervisor to sign the Employee Conflict of Interest Memo of Understanding.

    Home Study:

    If the applicants reside in one of AGCI’s licensed states, the applicants will complete their home study through an AGCI-identified cooperating agency.

    1. Adoptive applicants will be provided with the list of cooperating agencies in AGCI-licensed states.

    2. Home study will be conducted by a cooperating agency.

    3. Home study will be reviewed and approved by AGCI.


    During the paperwork and waiting stage of the adoption process the potential adoptive
    parents file will only be accessible to their program director, the Vice President of Adoption and the Vice President of Administrative Services.


    Depending on the program, review of a specific referral may return to the Special Consideration Committee before a referral is made to the family. If adopting from a Hague country, the Central Authority in the sending country will issue the referral directly to the family.

    1. Program director receives referral from non-Hague country or locates a child on the CCWAA databank in the China Special Needs Program.

    2. Program director requests that the Vice President of Adoption convene the Special Consideration Committee.

    3. Program director presents the referral information to the Special Consideration Committee.
    a. Provide the approved parameters for the family.
    b. Present the child information.
    c. Provide the committee with a list of all families the child could be placed with.
    d. Provide the committee with each family’s stage in the adoption process or position on the wait list.

    4. Committee members will consider if the referral is in the best interest of the child.

    5. Committee members will evaluate if the referral is the best fit for the family.

    6. Committee members will decide if the referral to this family is fair to other waiting families.

    7. The Committee will notify the program director if the referral can be given to the family.

    8. If determined by committee, the program director will make the referral to family.


    While the adoptive family is in country for their adoption, all calls will be addressed during business hours. Adoptive families should only contact their designated program director if issues arise during travel.

    1. Adoptive families may not ask for special travel arrangements (i.e., hotel, flights, etc.), extra visits with their child or any services that may be considered preferential by other clients.

    2. Applicants will sign a second memo of understanding at travel.


    All post-adoption reports and support will be provided by the agency that completed the original adoption home study. At this stage the adoptive parents file will only be accessible to the Post-Adoption Coordinator, Adoption Paperwork Coordinator, Vice President of Adoption and the accounting department.


Stewardship Report:

AGCI 2013 Financial Report
AGCI 2012 Financial Report
AGCI 2011 Financial Report

IRS Form 990

Form 990 2012
Form 991 2011

Policy Documentation

Whistleblower Policy
Records Retention Policy
Conflict of Interest Policy
Privacy Policy
Giving Policy

All God’s Children International does not sell, trade or share a donor’s personal information outside the organization. When AGCI partners with other organizations (public, private, nonprofit or government) to fulfill its ministry of serving orphans around the world donor information remains confidential and is not disclosed to partner entities unless the donor gives specific permission to do so.