2015 GNYADA Employee Handbook

Full disclosure in writing. Employees will be required to make full disclosure annually of

the existence and the nature of any potential conflicts and should be updated annually.

Although this is not a comprehensive list of circumstances that may arise, it is intended to

provide general direction regarding what could constitute a conflict of interest:

 having an ownership interest either directly or indirectly in a third-party organization

that conducts business with GNYADA;

 receiving undisclosed personal gifts or favors from a third party conducting business

with GNYADA;

 receiving preferential treatment from a third party conducting business with

GNYADA, including favorable terms in negotiating personal loans or insurance

policy premiums; and

 influencing results of solicitation contracts where personal benefits are solicited or

received in exchange for winning bids.

Possible conflicts of interest will not preclude GNYADA from doing business with a related

party. However, relationships with related parties will be considered only under the same

terms and selection processes as other vendors.

DISCLOSURE OF CONFLICTS OF INTEREST IS REQUIRED: All conflict of

interest in transactions must be disclosed to Mark Schienberg, President, or Rose Macleod,

Vice President and Director of Operations, who will then determine whether disclosure is

required to the Board of Directors or the Executive Committee, at which time the Board or

Committee will determine whether to evaluate and/or ratify transactions.

Exceptions: Transactions which are minimal in nature – for example, less than $250 in a

calendar year – or which are more then $250 but represent repeated transactions with vendors

where the conflict of interest has previously been disclosed and approved by the Board of

Directors or the Executive Committee may not require disclosure.

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