This Conflict of Interest Policy provides clarity about what constitutes an actual, potential or perceived conflict of interest and communicates a process for disclosing any such conflicts to the Company. It also helps guide the Company on how to manage any such disclosures, and the key factors to consider before making a decision.

Use this Policy if:

• You need to create a process for the disclosure of any conflicts of interest that your employees may have;
• You want to ensure that your employees are aware of their obligations regarding any conflicts of interest;
• Your management team need clarity on how to record and monitor any disclosed conflicts of interest;
• You want to clarify what constitutes a conflict of interest; and
• You would like to communicate how any disclosed conflicts of interest are managed, and establish the options available to the Company in managing these.

What does this Policy cover?

• Employee obligations around notifying the Company of any actual, potential or perceived conflicts of interest;
• Clarification on what constitutes a conflict of interest;
• The process for declaring any conflicts of interest; and
• The Company’s process for managing any disclosed conflicts.

Further Information:

• How to manage conflicts of interest in the workplace
• Conflicts of interest: how to avoid them
• What legal services do I need to hire an employee?
• Employee Handbook