August 17, 2023

Within the financial descriptions on the Polaris Project’s tax submissions, a page labeled ‘Schedule O’ breaks down protocols that prevent a conflict of interest within the organization. It reads, “Procedures include the duty to disclose, determine whether a conflict of interest exists, and addressing any real or potential conflicts. Polaris implements this practice before every significant discussion and board vote.”

While it is good that Polaris has a conflict-of-interest policy while working closely with large corporations, and government entities, do they follow it? A vote on a conflict of interest is hardly a stronghold against corruption, when many of the voting members are those heads of government, and business tycoons.

For instance, Mark Lagon, a former Ambassador at Large to Combat Trafficking in Persons, the very office established by legislation to manage and grow anti-trafficking efforts through grants, was also the CEO of Polaris Project, from February 2009 to February 2010. This appointment came just one month after the end of his former position as, Ambassador for the Department of state. With a hefty first year salary at $134,768, and a spot at the top of the list as the “highest paid executive”, who can say no? During the one year and one month tenure at Polaris Project, Lagon made a total of $187,214 in compensation.

Did anyone vote on this conflict of interest? On Lagon’s own LinkedIn, his role as Ambassador at Large, would lead the Office to Combat Human Trafficking’s “Programmatic Assistance to NGO’s”.

Mark Lagon LinkedIn

We know for a fact Lagon and Polaris would have a close working relationship. Seeing as how Polaris Project was elected to launch the National Human Trafficking Hotline by the very department Lagon headed in 2007.

When Polaris Project launched the resource center that would become the National Human Trafficking Hotline, they worked in tandem with Lexis Nexis and Sales Force as listed in the 2008 & 2009 return below. Lexis Nexis announced the partnership in 2009 on their website.

 “Polaris Project deeply values the working partnership LexisNexis has forged with us.  In advancing the Polaris-run National Human Trafficking Resource Center, through innovative analytics solutions from LexisNexis, we are together advancing the Rule of Law in the name of the most disempowered.”

Mark Lagon

One would think the CEO of Polaris would have contact and correspondence, during their employment, with Lexis Nexis while establishing the private partnership. We can only speculate the closed-door benefits and details of the partnership but, whatever they may be, Mark Lagon had to have made quite the impression since, in March of 2010, a month after his departure from Polaris Project, Lagon was hired as a Senior Advisor.

Mark Lagon on LinkedIn

In addition to the already concerning conflicts of interest at play, it is important to note that upon the departure of Lagon, Bradley Myles took over as CEO. Myles is the Husband of Polaris Project founder, Katherine Chon. There are obvious conflicts of interests that arise, seeing as how Katherine Chon, is and was the Director of the Office on Trafficking in Persons, while Myles was the CEO of Polaris Project. Meaning, her office was responsible for awarding the funding that would fuel the programs (and salaries) within Polaris Project. But that isn’t the only concerning conflict of interest between the two. The establishment of the relationship was within the organization.

In a Washinton Post article published in 2013, they were the center of a piece titled ‘On Love: Katherine Chon and Bradley Myles’. In this article, the newlyweds told the story of how they met and became husband and wife. Chon details how she met Bradley at a 2004 networking dinner, and then again at an event hosted by Polaris. That year, Myles began to volunteer with Polaris Project and by April of 2005, secured his first position as National Program Coordinator. One year and seven months later, Myles is promoted to National Program Director, in October of 2006. By late 2007, according to the WP, Myles was told by his therapist that while he was “superficially friendly”, he “rarely let people into his life enough to be truly open and vulnerable”. When disclosing this to Chon, her response to that, as his Executive Director, was to suggest that they “spend time together”.

Once or twice a week, the two made dinners together, went on long runs or watched movies. They discovered that beneath their vastly different exteriors were very similar core values.

The Washington Post

By Spring of 2008, they went public with their affection, and in the article by WP, Chon was “worried that a romance could interfere with their professional dynamic”, but continued to date Myles. That year, Myles was also promoted to Deputy Director. The article states that by August 2008, they were dating exclusively. So one would expect, when taxes are filed in 2009, the conflict of interest would be addressed.

By spring, Kat was beginning to realize her feelings for Brad ran deeper than just friendship. She worried that a romance could interfere with their professional dynamic — by then Brad was the deputy director of Polaris — and that it could be disruptive to the organization.

The Washington Post

As required on the ‘Government, Management, and Disclosure’ portion of the tax form, Polaris is required to answer questions about their policies in a conflict of interest. Below you see an example of tax year 2011, in which Polaris answers ‘yes’ when asked if “officers, directors, or trustees, and key employees” were required to disclose annually, conflicts of interest. In Schedule-O of the tax forms, they expand on the potential conflict of Derek Ellerman, the Co-Founder of Polaris, and Mei-Mei Ellerman, his mother, serving together on the board.

2011 Polaris 990

Strangely enough, in the 2008 tax year, that was prepared in 2009, the answer to the conflict of interest questions change.

Here you can see Polaris answer that they do not consistently monitor conflicts of interest, and that they do not enforce compliance. When checking to see if the budding romantic relationship was addressed in Schedule-O, similar to the way Ellerman’s was, we were disappointed to find nothing about it. From the standpoint of professionalism, this relationship was ethically misguided. As an Executive title holder, Chon was in a position to pressure Myles. From a conflict of interest standpoint, Chon votes on promotions and salaries. Was she omitted from the vote on Myles?

The United States Health and Human Services Department

In 2009, Chon stepped away from a direct oversight role to President of Polaris, so she could focus on her schooling at Harvard Kennedy. While Mark Lagon stepped up to fill the management role, Chon was being groomed for her next position that would pose new conflicts of interest. In February 2010, Myles steps up as CEO, and Lagon leaves to Lexis Nexis. Three years later, Chon completes her Masters of Public Administration and is hired as Senior Advisor on Trafficking in Persons. In 2015, Chon becomes the Founding Director of the Office on Trafficking in Persons, with Myles still holding his position as CEO.

According to John Hopkins University website, Chon’s function as Director of the OTIP is to oversee the budget which “funds grant programs”.

John Hopkins University Alumni

How much is the budget that Chon controls? Over the last five fiscal years listed in the table, Chon has managed a total of $103,775,000 in appropriated funds to the OTIP.

With these figures and details in mind, there are quite a few conflicts of interest that are seemingly ignored by Polaris Project, and the government entities that fund them.