Conflict of Interest Policy Adopted May, 2010

RESOLVED, that the following conflict of interest policy become the policy of this corporation and be applied to professional nonprofit employees. It is imperative that employees of the Nonprofit Organization conduct themselves with a degree of honesty and integrity that is beyond reproach or even suspicion.

While it is not possible to anticipate every situation and prescribe a precise rule for each, it is possible to set forth certain basic, general principles to be observed by employees at all times. The essence of this policy is that employees shall always deal with others doing, or seeking to do, business with the Nonprofit Organization in a manner that excludes all consideration of personal advantage. Accordingly, every employee of the Organization is subject to the following policy:

(a) Interest in Other Business Organization

Employees of the Nonprofit Organization thereof or members of their immediate families shall not have any interest, direct or indirect, in any other business which in any degree conflicts with the employee’s primary obligations to the Nonprofit Organization thereof. In this regard, employees or members of their immediate families should not possess a significant financial interest in any business that does, or seeks to do, business with the Nonprofit Organization thereof. In addition, employees should not conduct business on behalf of the Nonprofit Organization thereof with members of their immediate family, or a business organization with which the employees or members of their immediate families have any association that could be construed as significant in terms of potential conflict of interest.

(b) Gifts, Favors, Entertainment, and Payments to Employees

Employees shall not seek or accept any gifts, payments, fees, services, valuable privileges, vacations or pleasure trips, loans (other than conventional loans from lending institutions), or other favors from any person or business organization that does, or seeks to do, business with the Nonprofit Organization. No employee shall accept anything of value in exchange for referral of parties to any person or business organization that does, or seeks to do, business with the Nonprofit Organization thereof. In the application of this policy:

1. Employees may accept common courtesies of nominal value usually associated with accepted business practices for themselves and members of their families.
2. An especially strict standard is expected with respect to gifts, services, or considerations of any kind from suppliers. Entertainment at the expense of suppliers beyond that contemplated by (a) above should not be accepted under any circumstance.