SCORE Volunteer Code of Ethics and Conflict of Interest Guidelines 

 

Effective Date:

July 1, 2026

 

Purpose:

As a nonprofit resource partner of the U.S. Small Business Administration (SBA), SCORE’s mission is to foster vibrant small business communities through mentoring and education. SCORE volunteers are expected to uphold the highest standards of ethics, professionalism, and accountability to maintain public trust and effectively serve small-business clients.

 

This Code of Ethics and Conflict of Interest Guidelines sets expectations for ethical behavior, impartiality, and integrity in all SCORE activities. 

Applicability/Scope:

This Code applies to all SCORE volunteers acting in any capacity, including but not limited to:

 

• Mentors and subject matter experts
• Workshop presenters and trainers
• All Chapter Committee Members
• Operational support volunteers 

 

* Contracted Administrators should complete their respective employer’s Code of Ethics.

 

Volunteers are representatives of SCORE and are expected to conduct themselves in a manner that reflects positively on the organization at all times. 

 

Standards of Ethical Conduct

Integrity and Respect

• Always adhere to the SCORE mission and values.
• Treat all clients, volunteers, partners, and Headquarters staff with dignity and respect.
• Maintain a professional tone and demeanor in all SCORE-related activities, including mentoring sessions, events, communications, SCORE meetings, and public appearances. Profanity of any kind is not acceptable.
• Any form of harassment, including sexual harassment, or discriminatory behavior based on race, color, national origin, sex, age, disability, or any other protected characteristic is strictly prohibited. Harassment includes, but is not limited to verbal, non-verbal, or physical conduct that denigrates or shows hostility toward an individual on the basis of a protected characteristic that has the purpose or effect of creating an intimidating, hostile, or offensive environment; or has the purpose or effect of interfering with an individual’s performance or ability to perform their assigned duties.
• Do not discriminate against any individual based on race, color, religion, sex (including sexual orientation, gender identity, and pregnancy), national origin, age, disability, marital status, veteran status, or any other status protected by federal, state, or local law. 
• Do not engage in behavior—whether verbal, written, physical, or online—that undermines or damages SCORE’s mission, reputation, operations, or the dignity of its members, clients, and partners. 

Abiding by the Law

• Comply with all applicable local, state, and federal laws, including those governing nonprofit organizations.
• Adhere to all regulations and requirements associated with SCORE’s federal grant funding, including Office of Management and Budget (OMB) Uniform Guidance and SBA-specific grant-administered terms.
• Consult with SCORE staff whenever there is any question or concern about legal compliance.

Mentoring and Education Standards 

• Provide mentoring and advice without personal bias or expectation of reward.
• Always place the business interests of SCORE clients first.
• Never judge a client or their ideas and strive to build long-term relationships with all clients by utilizing the SLATE SCORE Mentoring methodology.
• Ensure that every client is aware of the ongoing services and resources available to them from SCORE.
• Adhere to the SCORE workshop Presenter Guidelines whenever presenting materials in a SCORE capacity.
• Accurately record and report all mentoring sessions, workshops, and client interactions in ENGAGE, SCORE’s designated system promptly, in accordance with organizational guidelines, Mentoring Minimum Standards, and reporting requirements.

Confidentiality

• Maintain the confidentiality of client information obtained through mentoring or SCORE programming.
• Adhere to SCORE’s Social Media Policy, Personal Information Protection Policy, and AI Ethical Use Policy when handling client information or engaging in public communications, including on personal social media accounts.
• Do not sign any confidentiality agreements or any Non-Disclosure Agreements (NDA) with clients. SCORE volunteers are required to complete annual Code of Ethics training, acknowledging their understanding and compliance. 
• Do not disclose client details without their explicit consent, unless legally required. Disclosure requires approval from SCORE HQ Compliance.
• Respect the confidentiality of SCORE’s internal information, including strategic plans, internal communications, financial data, and operational decisions, and do not share such information outside the organization without authorization. Non-public SCORE information encompasses all data/information that requires SCORE systems log-in and password, unless disclosed elsewhere publicly.  Any disclosure requires approval from HQ Compliance.
• Continue to protect the confidentiality of client information, organizational data, and proprietary materials. The responsibility extends beyond the conclusion of a volunteer’s service with SCORE and remains in effect indefinitely.

 

Political Neutrality

As a grant-funded organization, SCORE must maintain strict political neutrality in all operations and volunteer activities. To uphold this standard:

 

• Do not engage in political discourse or advocacy, communication, or opinions while acting as a representative of SCORE.
• Ensure all meetings—whether with Headquarters staff, volunteers, clients, or partners—remain focused on SCORE’s mission and small business support.
• Do not use SCORE events, workshops, or communication platforms to promote or share political opinions or candidates.
• Always treat clients, staff, and fellow volunteers with respect, regardless of political beliefs.
• Apply these principles consistently in all interactions, including those with external partners and the public, including social media.

 

Use of SCORE Resources and Brand

Volunteers are entrusted with SCORE’s brand and resources and are expected to use them responsibly and in accordance with SCORE policy.

 

• Volunteers must not use SCORE materials, facilities, branding, or communications platforms for personal business or gain.
• Follow the official FY2027 SCORE Brand Guide when using logos, colors, templates, or other branded materials.
• Use SCORE branding only for SCORE-approved activities; do not co-brand with outside organizations or imply endorsements without authorization.
• Do not use the SCORE or SBA logos in connection with personal, political, or non-SCORE-related initiatives.
• Use SCORE email, websites, facilities, and systems solely for SCORE business.
• Understand that all SCORE materials, including presentations, templates, training documents, and digital content, are the intellectual property of SCORE and may not be copied, modified, or distributed for personal or external use without prior written approval.
• Protect and appropriately use SCORE-issued equipment (e.g., laptops, tablets, printers) and materials; you are responsible for their care and return when no longer in use. Register all new electronic devices by submitting the device brand, model number, and location to [email protected]. 
• Do not repurpose SCORE software licenses, databases, or subscriptions for personal or non-SCORE purposes.
• Do not store or transmit sensitive client or SCORE information on unsecured personal devices or cloud platforms.
• Follow SCORE’s Equipment Policy and return all SCORE-issued equipment and materials upon ending your volunteer service or upon request.

 

Conflicts of Interest

Volunteers must avoid actual or perceived conflicts of interest between their personal interests and the interests of SCORE or its clients.

 

The purpose of this Conflict of Interest addition is to safeguard SCORE’s interest when it is contemplating entering into a transaction or arrangement that might benefit the private interests of a volunteer of the organization or any individual acting on SCORE’s behalf. 

 

This policy supplements, and does not replace, applicable state and federal laws governing conflicts of interest for nonprofit and charitable organizations. SCORE is also required by certain funders—including federal agencies—to comply with the Code of Federal Regulations, Title 2, Part 200.112. Under this provision, recipients of federal funds must disclose in writing any potential conflict of interest to the awarding agency or pass-through entity. This requirement applies to anyone acting on the organization’s behalf, including unpaid staff and volunteers.

 

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.

 

A Financial Interest is not necessarily a conflict of interest. A person who has a Financial Interest may have a conflict of interest only if the appropriate SCORE leadership or designated committee decides that a conflict of interest exists.

 

Volunteers may not:

• Recommend products, services, or vendors in which they, their family members, or close associates have a financial or controlling interest.
• Solicit clients to become personal customers, business partners, or investors.
• Become an officer, director, shareholder, investor, or partner of any for-profit client, or provide direct funding to any SCORE client that you 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.

Volunteers may:

• Participate in the vetting, recommendation, or support of SCORE partners, tools, or sponsors when doing so aligns with SCORE’s mission and they receive no personal benefit.
• Promote SCORE-approved resources or partnerships during authorized activities.
• Serve on nonprofit boards, provided such service does not result in personal financial gain or create a conflict of interest with SCORE clients (e.g., mentoring a client who applies for funding from that nonprofit).

 

Disclosure Requirements:

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 or perceived conflict

 

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

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.

 

Duty to Disclose:

Volunteers shall disclose in writing (and update at least annually) all Financial Interests that may create an actual or potential conflict of interest. When in doubt, at any point, disclose. Disclosure protects both the volunteer and SCORE.

 

Volunteers must promptly disclose any actual or potential conflicts of interest to SCORE Headquarters (HQ) ([email protected]). Disclosure enables appropriate management of any issues and does not imply misconduct.

 

Disclosure Process:

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 required annually by October 1, or at any point as soon as a potential conflict is identified.

3.  Review by SCORE HQ

•   All disclosures will be reviewed by SCORE Compliance and the Vice President of Field Operations.

 

SCORE Volunteer Conflict of Interest Disclosure Form:

A copy of the Conflict of Interest Acknowledgement Form can be accessed here and on the Support Center.

 

Review Process and Outcomes:

SCORE Compliance and the Vice President of Field Operations will review the disclosure and determine whether any action is required.

• If the Volunteer does not receive notification within 10 business days, they may assume:

• The disclosed conflict is not a compliance concern and is, therefore, acceptable; and

• No further action is required at the 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/as appropriate

 

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

 

Violations of the Conflict of Interest Policy: 

 

If SCORE has reasonable cause to believe that a volunteer has failed to disclose actual or possible conflicts of interest, the organization shall inform the volunteer of the basis for such belief and allow the volunteer to explain the alleged failure to disclose. 

 

If, after receiving the volunteer’s response and after making such further investigation as may be warranted by the circumstances, the organization determines that the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary action.

 

Confidentiality:  Volunteers must protect all confidential, proprietary, financial, and copyrighted information belonging to SCORE. Volunteers shall not disclose, directly or indirectly, any confidential information to any person, institution, entity, or third party in connection with activities performed on behalf of SCORE.

 

These confidentiality obligations apply throughout the term of volunteer service and survive the expiration or termination of the volunteer relationship, regardless of the reason for termination. All confidential and proprietary information disclosed or accessed remains the sole property of SCORE.

Upon termination of service, or upon SCORE’s request at any time, volunteers must promptly return all confidential or proprietary materials and shall not retain copies, extracts, notes, or reproductions in any form.

 

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 termination.

 

Frequently Asked Conflict of Interest Questions

Common Situations That May Require Conflict of Interest 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.

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.

 

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.

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.

 

 

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.

 Financial or Personal Interests

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

 

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.

Questions or Concerns?

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

[email protected] or contact your Field Leader directly. 

SCORE appreciates your commitment to transparency and ethical service.

 

Note on Volunteer Status:

SCORE volunteers serve in a non-compensated, volunteer capacity. Nothing in this policy or any related activity shall be construed to create an employment, agency, or legal partnership relationship between the volunteer and SCORE, the Federal Partner, or any third party. Volunteers do not have the authority to bind SCORE or make commitments on its behalf unless expressly authorized in writing.

Reporting and Compliance

Reporting

Volunteers are encouraged to report suspected ethics violations, misuse of SCORE resources, or inappropriate conduct. Reports may be submitted to:

• Field leadership (Chapter Chair, District Director, Regional Vice President)
• Vice President,  Field Operations
• SCORE Compliance 
• SCORE HQ ([email protected])
• Confidentiality via SCORE’s Whistleblower Policy (including the SBA whistleblower hotline) if the violation rises to the requirements listed.

 

Retaliation Protection

Retaliation for good-faith reporting is strictly prohibited.

 

Noncompliance

SCORE reserves the right to take appropriate action, including restricting volunteer privileges or terminating volunteer service, based on a violation of this Code or other SCORE policies. Nothing in this Code creates a contract, promise, or entitlement to continued volunteer service.

Policy Owner:

SCORE Compliance

 

Policy Owner:

Compliance

 

Title: 

Director, Compliance

 

Department:

Governance