CONFLICTS OF INTEREST POLICY 

RESPONSIBILITY: Helpuaro Board
DATE ISSUED: 1 June  2022
DOCUMENT NUMBER: HP N 1/ 1.06.22
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POLICY STATEMENT
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All employees, Board members and volunteers of foundation Hromadahub are required to perform the duties and activities of their position with the highest level of integrity and independence, in a professional and ethical manner. They must also ensure that they avoid or eliminate any conflict of interest or situation that could reasonably be perceived as a conflict of interest and immediately report it to their manager.Although this policy details certain behaviours that may lead to a conflict of interest or the appearance of a conflict of interest, it is impossible to anticipate all situations that could lead to one. Employees or volunteers may also inadvertently find themselves in a situation that leads to or could be perceived as a conflict of interest. These situations must also be disclosed.Compliance with this policy is a condition of employment. Failure to comply with these provisions may result in disciplinary action, up to and including termination of employment.
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SCOPE

This policy applies to all employees, Board members and volunteers of Hromadahub as well as contractual third parties or partners doing activities with the foundation. All are expected to abide by the provisions of this policy that are reasonably applicable to them.
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ACTION OR BEHAVIOURS TO AVOID

Below, you will find some situations, behaviours or events that should be avoided at all costs by employees, managers, volunteers or other contractual third parties doing activities or business with the foundation.
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PERSONNAL INTEREST

Employees must ensure that no conflict exists or could appear to exist between their personal interests and those of Hromadahub potential customer, partner, vendor, supplier or other entity in which you have a direct or indirect financial interest.
Employees or volunteers must not:
Take part in or attempt to influence any Hromadahub decision or any business dealings with a current or potential customer, partner, supplier or other entity in which you have a direct or indirect financial interest;
Use the premises, equipment, supplies or services of other employees or volunteers of Hromadahub to promote their personal interests;
Use confidential information for their personal benefit during or after employment with Miloserdie;
To be in a position where they could benefit directly or indirectly from a Hromadahub transaction (e. g. supplier of goods or services, contract, license or partnership);
Give preferential treatment to any supplier or other person dealing with Hromadahub order to serve their personal interests;Invest in, own, have an interest in, or be an employee of an organization that might have an interest, direct or indirect, in any Hromadahub transaction, except in the case of a widely held public company whose dealings with Hromadahub do not represent a substantial portion of its total business;
This should not be interpreted as an exhaustive list of all circumstances that could lead to a real or perceived conflict of interest.
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FAMILY, FRIENDS AND ROMANTIC RELATIONSHIPS
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Employees, volunteers and managers must not:
Use their position or contacts at Hromadahub to promote their personal interests or those of a family member or person with whom they have a close personal or professional relationship;
Take part in or attempt to influence any Hromadahub related decision or business dealings (including those concerning current or potential customers, partners, vendors or suppliers) that may benefit or appear to benefit a relative, close personal friend or an entity which a relative or close personal friend is involved or has a direct or indirect financial interest;Hromadahub generally does not permit work situations where a manager directly or indirectly manages a relative or a person with whom he/she has a romantic relationship. If you are aware that Hromadahub plans to hire your relative or a person for a position with whom you have a romantic relationship that directly or indirectly reports to you, you must disclose that information immediately;If, during the course of your employment, a romantic relationship develops between you and another Hromadahub employee within your direct or indirect reporting chain, you both must promptly disclose that information. Although employees involved in a consensual relationship are individually responsible for disclosure, a manager's failure to report such a relationship will be grounds for appropriate disciplinary action.
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RELATIONSHIPS AND FAVOURITISM
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Employees or volunteers shall not grant or appear to grant preferential treatment to a person with whom they have a close personal or professional relationship. In some situations, past relationships may also give rise to a perceived conflict of interest and should be treated as such.
If an employee or volunteer is in a situation where he or she could make a decision (e. g. hiring, evaluation, discipline, promotion, reward, any other form of discretionary control or the awarding of a contract) involving, directly or indirectly, a person with whom he or she has a close personal or professional relationship, the employee must:
Disclose the potential conflict to his/her manager
Refer the decision to the manager or someone designated by him/her
Refrain from making any recommendations or conveying views related to the decision.
In addition, if an employee or volunteer is in a position of authority over a person with whom he or she has a close personal or business relationship, the manager must change the hierarchical relationship between the employee or volunteer and that person. The manager may also take other measures to reduce the appearance of conflicts of interest, if necessary.
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OUTSIDE ACTIVITIES
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Employees or volunteers are permitted to engage in outside employment or activities as long as they inform their manager prior to starting such activity, and to the extent that:
It does not compete with or reflect adversely on Hromadahub or give rise to a conflict of interest;
It does not engage in any outside activity that is likely to involve disclosure of Miloserdie’s proprietary information or that is likely to divert time and attention from your responsibilities at Miloserdie;
It could not be reasonably perceived as compromising the integrity, independence and impartiality expected from Hromadahub or bring Hromadahub into disrepute;
It does not inappropriately exploit the employee’s connection with Mioserdie;
It does not restrict your availability or efficiency;
It does not involve acting as a spokesperson for another organization;Employees or volunteers are permitted to act as board members of an organization external to Hromadahub if their participation meets the criteria above, and if authorized by their manager beforehand;Employees or volunteers may be permitted to write books or work on other creative projects that are not in competition with Hromadahub as long as they respect the criteria for outside activities mentioned above and obtain prior written authorization from their manager.
Employees or volunteers are not required to seek approval of the following activities:
Any affiliation with an association, professional association or other such organization related to your work or position at Miloserdie;
Participation in non-profit civic or charitable activities, including serving as a member of a board of directors or technical advisory board. However, you must obtain approval if the entity is an Hromadahub customer or expects to receive or seek a contribution from Miloserdie;
Positions with co-op boards, condominium associations and similar entities where the sole purpose of such participation would be to hold title to and/or manage real property in which you can or do reside;
Positions with holding companies, trusts or other non-operating entities established solely for purposes of you or your family’s investment, estate or tax planning or to hold you, your family’s real estate or other investments that would not otherwise require disclosure under this policy.If the manager considers the outside activity to be inappropriate, considering the criteria mentioned above, it must inform the employee or volunteer in writing and the employee must avoid, discontinue or modify his/her participation in such activities accordingly. Disclosures and their assessment by the manager must be documented.
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GIFTS, HOSPITALITY & OTHER BENEFITS
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Accepting a gift, a benefit or an offer of hospitality for oneself or for a colleague, family member or friend can lead to uncomfortable situations or to real or perceived conflicts of interest.
Employees or volunteers may occasionally accept unsolicited gifts, hospitality, free travel, tickets, or invitations to sports or entertainment events (e.g., baseball/football game, round of golf, theatre show or concert) or other benefits, but only if they have a value of $ 200 or less, subject to the conditions expressed below. It is also permitted to occasionally accept a working meal of reasonable value paid for by a third party.
However, employees or volunteers must not accept gifts, hospitality, free travel, tickets, or invitations to sports or entertainment events or any other benefits:
That could influence, or be perceived to influence, their judgment and/or their performance of duties;
That are offered by a partner and/or supplier of goods or services involved in an active request for proposal, sole source contract procedure or contract discussions, or in the six months following such a process, or as soon as they know such a process will begin in the near future;
That are offered by a partner and/or supplier whose performance the employee or volunteer is evaluating;
That are cash, loans, discounts or work rendered free of charge for personal purposes;
If the total value of what has been received from the same source within a 12 months period would exceed $ 800.
In circumstances where refusing a gift worth more than $200 would prove rude or problematic, an employee is permitted to accept it; however, it becomes the property of Hromadahub and must be handed over to the employee’s or volunteer’s manager, who must decide how best to dispose of it.
Employees or volunteers must also refuse invitations to a conference or other formal gathering not mentioned above, organized or sponsored by an external party, a supplier, potential supplier or partner, unless their manager determines that their attendance at such an event would not compromise or appear to compromise the objectivity, independence, impartiality or integrity of the employee or volunteer of Miloserdie.


EMPLOYEE or VOLUNTEER AGREEMENT ON CONFLICTS OF INTEREST POLICY

I have read, understand, and agree to comply with the foregoing policy, rules, and conditions governing the Conflicts of interest policy. I am aware that violations of this policy may subject me to disciplinary action, including termination from employment, legal action and criminal liability. Furthermore, I understand that this policy can be amended at any time.

DATED: _______________________

EMPLOYEE or VOLUNTEER _____________________________


Hromadahub__________________________________________