Conflict of Interest Policy

CAREER TRANSITION INSTITUTE

CONFLICT OF INTEREST POLICY AND PROCEDURES

Updated 6/3/2013

Members of the Board of Trustees (“Trustee”) of Career Transition Institute (“the organization”) are not permitted to vote upon or otherwise participate in any transaction in which he/she has a financial or personal interest, or that would result in securing for the trustee any advantage, benefit or privilege.

PROCEDURES

1. Each trustee of Career Transition Institute shall, in the course of his/her duties, act with strict duty, loyalty and fidelity to the best interests of the organization, exercise the utmost good faith in all matters or transactions, and adhere to the highest ethical standards of fiduciary duty.
2. Each trustee shall endeavor to avoid, to the best of his/her ability, any situation which might result in a compromise of his/her duty to Career Transition Institute, due to a conflict of interest relating to any other organization(s) which the trustee may be involved. Each trustee shall endeavor to avoid even the appearance of a conflict of interest, which may have an adverse effect on the reputation of the organization.
3. Each trustee shall disclose to the Board of Trustees any potential conflict of interest he/she has.

Such disclosure shall be made in writing on the form attached to this policy; he/she shall identify any material, financial or other beneficial interest held by the trustee or his/her immediate family in any organization(s) engaged in the same business or services as Career Transition Institute or engaged in delivery of products or services to the organization.

1. Any trustee having a potential conflict of interest in connection with a matter before the Board, such that the trustee cannot in good faith act with undivided loyalty to Career Transition Institute, shall abstain from voting or taking part in any Board action or activity on the matter.
2. Such officer or trustee shall refrain from exercising personal influence on the matter.

In the event of a disclosed interest which a trustee believes will not affect his/her loyalty to the organization, an open and frank discussion of the interest and the matter in question shall be held by the Board of Trustees in the absence of the interested trustee. The Board shall then decide whether the trustee shall be recused from action and/or discussion on the matter.

1. All disclosures of potential conflicts of interest and all abstentions from voting or other activities due to potential conflicts of interest shall be noted in the minutes of meetings concerning the matter in question.
2. A disclosed interest shall not prevent the Board of Trustees from taking any action on the matter in question, provided an open and frank discussion takes place. Nor shall the disclosure of such interest prevent the Board from making any inquiries or obtaining such information or assistance from the trustee in question as it deems advisable under the circumstances.
3. Each trustee shall refrain from using any information or opportunities gained in his/her role as a trustee for personal benefit or gain or for the benefit or gain of any organization with which he/she may be involved, without prior disclosure to and expressed written approval from the Board of Trustees.
4. The Board of Trustees shall review at least annually this Statement of Policy and Procedures hereby adopted, to ensure that potential conflicts of interest are being effectively addressed and managed. The Board shall advise each new trustee of this Statement of Policy and Procedures upon his/her election.
5. A Statement of Disclosure, a copy of which is attached, shall be completed and signed annually by each trustee. This record will be held on file in the corporate office by the Board secretary.
6. Each trustee shall provide additional written disclosures to the Board of Trustees if and when additional materials, financial or other beneficial interests become evident and if any potential conflict of interest develops within the meaning of this policy between annual reviews of this document and the execution of the trustee’s next annual Statement of Disclosure.